stark-Sinclair Community College 2010

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U.S. Department of Transportation Federal Aviation Administration NOV 1 9 2010 Donald Stark Airframe & Powerplant Coordinator Sinclair Community College 444 West Third Street Dayton, OH 45402-1460

Dear Mr. Stark:

Office of the Chief Counsel 800 Independence Ave., S.W.

Washington, D.C. 20591 This letter responds to the request for a legal interpretation that you mailed to this office on May 18, 2010. Specifically, you have asked whether you may instruct on diesel engines that are type certificated as reciprocating engines as part of an approved curriculum under 14 C.F.R. part 147, Appendix D.

Section 147.21 outlines the general curriculum requirements for an aviation maintenance technician school (AMTS). The approved "curriculum must cover the subjects and items prescribed in Appendixes B, C, or D, as applicable." 14 C.F.R. § 147.21(c). Appendix D sets forth the required powerplant curriculum subjects which include powerplant theory and maintenance for reciprocating engines. Although Appendix D does not specifically list diesel engines, a diesel engine, as a reciprocating engine, would be a proper subject for instruction under the Appendix.

We note that, notwithstanding the fact that a diesel engine may be included in the instruction of reciprocating engines, a school's curriculum must ultimately be approved by the Principal Maintenance Inspector, who is responsible for determining whether a curriculum will qualify "students to perform the duties of a mechanic for a particular rating or ratings." 14 C.F.R. § 147.21(a). The FAA has issued an advisory circular that provides additional guidance regarding the certification requirements for an AMIS including curriculum development. AC 174-3A, Certification and Operation of Aviation Maintenance Technician Schools, January 18, 2005. This document is available at http://rgl.faa.gov/Regulatory_and_Guidance_ Library/rgAdvisoryCircular.nsf/list/AC%2014 7-3A/$FILE/AC%2014?°-3A.pdf. .

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This response was prepared by Anne Moore, an Attorney in the Regulations Division of the Office of the Chief Counsel, and coordinated with the Aircraft Maintenance Division of Flight Standards Service. We hope this response has been helpful to you. If you have additional questions regarding this matter, please contact us at your convenience at (202) 267-3073.

Sincerely,

~~ {~Rebecca B. MacPherson Assistant Chief Counsel, Regulations Division