On June 15 the FAA released change 460 to the Flight Standards Information Management System, harmonizing inspector guidance with language in Advisory Circular (AC) 147-3B. The revision also institutes FAA inspector part 147 course attendance (also available to industry) and integrates the agency’s new compliance philosophy.
ATEC applauds the FAA for making needed revisions and adopting council-proposed language (see letters here, here and here). Further improvement can be made by removing continued reference to “makeup assignments” which ATEC maintains is not supported by the regulation.
Section 147.31(e) requires that AMTS show how missed material will be made available to students; FSIMS however states that “a student must complete all makeup assignments, class assignments, and exams missed in a module before an instructor can administer any written, oral, or practical test” and that “failure of a student to complete all makeup assignments and material within the school’s approved allotted time period may result in the student being required to repeat that subject” (see Vol. 2, Ch. 12, Section 2, paragraph 2-1449(G)). While some inspectors interpret the provision in the context of school policy and procedures, others seek to enforce prohibitive and prescriptive conditions that misallocate AMTS and agency resources. ATEC therefore requested that the provisions be removed in their entirety.
Even more concerning, the agency added a provision that “instructors cannot use the material from distance learning offerings to make up material missed from a classroom or lab offering, or vice versa.” While there are certainly limitations to what can be virtually taught (i.e., hands-on lab projects, etc.), the assumption that distance learning is substandard to “traditional” forms of teaching flies in the face of innovation, access to education and the good work of joint FAA/industry advisory committees. The manner in which material was originally taught should not dictate how it is subsequently made available, especially when technology provides the opportunity for unrestricted access.
ATEC will continually engage with its FAA counterparts to ensure internal government documents work in concert with the plain language of the regulation. Members are encouraged to submit feedback on this and other regulatory compliance matters to firstname.lastname@example.org.
A red-lined document outlining the specific changes in FAA Order 8900.1, Vol. 2, Ch. 12, Section 1, Section 2 and Section 3 and Vol. 6, Ch. 10, Section 1 is available here.
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