Early Testing and Authenticated Documentation

Q: I understand that the new part 147 allows our students to take the general test as soon as they’ve completed the general curriculum. What needs to be included on the required “authenticated documentation,” and what is the difference between the authenticated documentation required for early general testing, and the authenticated documentation required for a certificate of completion?

A: Before the new rule was published, most part 147 schools had an exemption from the FAA to allow their students to take the general knowledge test when the student completed that part of the curriculum. The new rule allows AMTS to provide students that opportunity without an exemption. (NOTE: If you have an exemption, it will expire under the new rule, no need to get it renewed.)
 
Here are the applicable parts of the regulation:
 

• Section 147.21 Certificate of Completion. Each certificated aviation maintenance technician school must provide an authenticated document to each graduating student, indicating the student's date of graduation and curriculum completed.

• Section 147.31 Early Testing. When a student satisfactorily completes the general portion of a certificated aviation maintenance technician school's curriculum, the school may issue an authenticated document that demonstrates the student's preparedness to take the mechanic general written test in accordance with § 65.75(c) of this chapter.

 
So, the FAA uses the term “authenticated documentation” in two places in the new rule: one as the evidence needed to take the FAA general knowledge test before graduation, and the other as the evidence needed to take the airframe and/or powerplant portions of the test after graduation.
 
Another difference: An AMTS is required to issue authenticated documentation to graduates under 147.21. An AMTS is not required to provide authenticated documentation evidencing completion of the general curriculum under 147.31, but without that authenticated documentation, the student is not eligible to take the general written test early.
 
What the authenticated documentation looks like is totally up to the program, it can be a letter or a certificate. Whatever form the program uses for its graduation certificates and/or certificates of completion in the past will work, so long as they include the following information: 

1. Student name
2. Organization name
3. Organization FAA Air Agency Certificate Number
4. Curriculum completed (i.e., general, general and airframe, general and powerplant, or general, airframe, and powerplant)
5. Graduation date or date the student completed the general curriculum (depending on if you’re issuing authenticated documentation for graduates or early testers)