On Feb. 15, ATEC submitted comments to draft Advisory Circular 147-3B. The AC provides guidance to part-147 aviation maintenance technician schools on curriculum and operating requirements.
A working group consisting of school representatives prepared the comments on ATEC’s behalf. Members of the working group included--
· Fred D. Dyen, Professor & Coordinator, Aviation Maintenance Technology Program, Blue Ridge Community College
· Ryan Goertzen, President, Spartan College of Aeronautics and Technology
· Paul Herrick, Professor, Aviation Maintenance Technology, University of Alaska Anchorage
· Kevin High, Associate Professor, Western Michigan University College of Aviation
· Charles E. Horning, Department Chairman, Aviation Maintenance Science, Embry-Riddle Aeronautical University
· Shannon McGurk, Corporate Director of Education, Aviation Institute of Maintenance
· Andrew Smith, Associate Professor, Aviation Maintenance Management, Kansas State University
The group’s comments suggested several modifications to the draft AC. Generally, the comments sought to ensure consistency with regulatory requirements and that the AC provides best practices and guidance as opposed to imposing new requirements. Specific recommendations included--
· Rewrite of the proposed appendix 11, addressing distance learning, including rejection of the 400 hour limit “imposed” by the AC.
· Modifications to operations specifications sections to ensure consistency with WebOPSS program.
· Removal of the question and answer (Q&A) appendices; specifically, Appendix 3 Frequently Asked Questions Regarding AMTS Certification and Operation and Appendix 4 Frequently Asked Questions Regarding AMTS Operations Specifications. The group noted that the Q&As are outdated and better suited for an online webpage where they can be frequently updated and revised.
· Rewrite of “missed material” section to ensure clarity of regulatory requirements (i.e., missed material availability vs. makeup time).
· Addition of paragraph encouraging dual-enrollment programs with accredited educational institutions.
· Rewrite of Appendix 12, “Letter of Compliance” such that it would provide a reference for both industry and government to ensure an institution’s compliance with the regulation.
The working group’s submission package is available for review at http://www.weebly.com/uploads/1/0/7/5/10756256/atec-ac147-3b-commentsubmission-web-20150214.pdf.
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