Q: Does testing time count towards required curriculum hours? Our school has been asked to adjust our curriculum so that hours for subject material testing is not included.
A: Including test-taking time in required curriculum is not prohibited in the regulation; the practice is supported by FAA guidance.
14 CFR § 147.21 provides the general curriculum requirements. Paragraph (d)(3) states that the curriculum “must show” a list of the minimum required school tests to be given. It is reasonable therefore to conclude that testing is included within the curriculum. That assertion is supported in several instances in associated guidance material:
While there is some confusion within the guidance (see Question 24 in the AC’s Appendix 3 which seems to confuse course testing with mechanic certification test prep, which is specifically excluded from required curriculum hours in the regulation); practically speaking, if tests are required to satisfy curriculum requirements, it follows that test taking time should be included in curriculum hour requirements.
If there is continued confusion at the local level please let ATEC know and we can help facilitate a consistency & standardization initiative (CSI) with your local flight standards district office.
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