Legal Interpretations
stark-Sinclair Community College 2010
Summary
The Question
May an aviation maintenance technician school teach diesel engines that are type certificated as reciprocating engines as part of its 14 CFR part 147, Appendix D curriculum?
Background
Sinclair Community College's airframe and powerplant coordinator asked whether diesel engines, though not specifically listed in Appendix D, could be included in its powerplant instruction.
The FAA’s Interpretation
Yes. Appendix D requires instruction in powerplant theory and maintenance for reciprocating engines, and a diesel engine, as a reciprocating engine, is a proper subject even though it is not specifically listed. However, the school's curriculum must still be approved by the principal maintenance inspector, who decides whether it qualifies students to perform the duties of a mechanic for a particular rating under 14 CFR 147.21(a).
- Requester
- stark
- Organization
- Sinclair Community College
- Issued
- November 19, 2010
- Subject
- Maintenance & Repair Stations
Regulations Cited
Page 1
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. .
Page 2
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
Regulations Referenced
Snapshot retrieved August 6, 2026.