ACS Working Group Makes Formal Recommendation to Align Part 147 with New Mechanic Knowledge and Skill Standards
A June 28, 2017 letter was formally presented at a recent Aviation Rulemaking Advisory Committee (ARAC) meeting, recommending that the FAA ensure part 147 is properly aligned with new airman certification standards.
The recommendation was initiated by the ACS working group, which warned against creating training standards in part 147. The group argues that the ACS should set the minimum knowledge and skill requirements for mechanic certification, as provided for in part 65. Part 147 has essentially set the standard through its curriculum requirements, which is misplaced.
The working group communicated these sentiments to AFS-350 through a formal recommendation asking that it 1) revise part 65 to provide the baseline standard for mechanic knowledge and skill requirements, 2) remove any reference to curriculum requirements or subject areas from part 147, 3) reference the AMT ACS in AMTS operations specifications to ensure that training and testing are directly correlated and 4) utilize the ARAC Airman Certification System Working Group as the driver for changes to training requirements.
Utah Senator Orrin Hatch made formal inquiry into the status of the anticipated revised proposal for 14 CFR part 147, the regulation governing curriculum requirements for aviation maintenance technician schools.
In addition to the update, Sen. Hatch highlighted the need for a rule that provides more flexibility:
"As you may know, Utah schools are home to many aviation education programs, including those for aviation maintenance technicians. I have repeatedly heard from constituents who wish to have updated, less burdensome regulations for these programs. I share in their concerns that the rule is in major need of an update to keep up with the expanding global aviation sector and modernized aircraft."
The FAA has stated than an SNPRM will be issued in October 2017.
The aviation maintenance technician school docket was recently revised to include a second NPRM in its regulatory plan timetable. According to the revision, a Supplemental Notice of Proposed Rulemaking (SNPRM) will be published in October 2017.
An SNPRM is generally issued when a proposed rule has been substantially changed from the original notice of proposed rulemaking. The supplemental notice advises the public of the revised proposal and provides an opportunity for additional comment.
Given developments with Airman Certification Standards since the original NPRM was issued, and strong comments by ATEC and other industry groups calling for a less prescriptive rule with opportunity for competency-based training systems, the council is optimistic that the revised proposal will provide a better framework for aviation maintenance school programs.
While the additional step will likely delay promulgation, ATEC is confident that another round of review and comment will help ensure the next iteration of part 147 will last the test of time. Stay tuned.
Council activities are ramping up in anticipation of new airman certification standards and a revised part 147. The webinar provides an overview of potential changes, tips on how to prepare, and access to practical resources so schools and companies alike can start planning now. Opportunities are available for all stakeholders to help ensure aviation maintenance technician school curriculum adequately prepares the future workforce.
All members receive free access to the recorded version, available in the ATEC Webinar Library.
ATEC is initiating a grassroots campaign to garner legislative support for expeditious issuance of the new part 147. To support those efforts, ATEC contributed an opinion article to a leading political publication, The Hill. The piece highlights the ever-growing need for a modernized regulation governing aviation maintenance technician training. It will be used to educate lawmakers on the issue during the council's annual Fly-In, held each year in Washington DC.
Read and share the article, found here: http://thehill.com/blogs/pundits-blog/transportation/345631-aviation-struggles-with-50-year-old-maintenance-training
Lots of behind-the-scenes activity is taking place in preparation for the new part 147. The expectation is that a new rule will be issued this summer, so it’s a good time to sit back, take a breath, and assess where we’re at, and opportunities coming down the pike.
First, a quick recap: Title 14 Code of Federal Regulations (CFR) part 147 governs aviation maintenance technician schools that hold a Federal Aviation Administration (FAA) certificate. The regulation was originally established under the Civil Aviation Administration and re-codified into 14 CFR in 1962. Since that time, neither the regulation, nor the subject areas it dictates be taught, have significantly changed. During the same time, the design regulations mandating the standards to which a civil aviation article must be certificated and maintained have changed innumerable times. These changes have enhanced safety significantly; they also mandate more sophistication and knowledge in maintenance personnel.
Everyone agrees the rule needs revising. A 2003 Government Accountability Report (GAO) report called for updates to curriculum requirements, recognizing that certificated programs do "not fully prepare A&P mechanics to work on commonly flown, technologically advanced commercial aircraft,” and that “today’s modern aircraft require A&P mechanics to have a different set of skills than those being taught at aviation maintenance technician schools.” An Aviation Rulemaking Advisory Committee, made up of industry and FAA representatives, issued a December 2008 report with specific recommendations to update static minimum curriculum requirements dictated in part 147.
Since then, ATEC has been at the forefront of the demand for change. In November 2015, the FAA issued a part 147 notice of proposed rulemaking. ATEC submitted extensive comments, calling for a less-prescriptive rule that would allow for competency-based programs and the freedom to cater training to industry needs. ATEC’s position was supported by 14 aviation organizations, discouraging the NPRM’s continued reliance on class time at the expense of technical capability. To continue the momentum, ATEC representatives held face-to-face meetings, submitted supplemental comments and garnered legislative support for a rule that would provide better trained personnel to meet industry workforce needs.
During roughly the same period of time, an FAA-industry working group undertook a massive effort to improve airframe & powerplant (A&P) mechanic certification testing. The Aviation Maintenance Technician (AMT) Airman Certification Standards (ACS) will replace current practical test standards (PTS), and clearly define minimum knowledge and skill requirements for A&P mechanics. Once completed, the ACS will provide the framework for the written, oral and practical mechanic tests; and subsequently, a guide for revising handbooks, oral questions, practical projects and the knowledge test bank. That means outdated questions and projects will be replaced with relevant assessment material, and incorrect, incomplete or inadequate questions and projects will be updated or removed.
Promulgation of the new part 147 and AMT ACS development couldn’t be more perfectly timed. The new rule will utilize operations specifications in lieu of static curriculum requirements; industry’s hope is that those operations specifications will simply reference the ACS, ensuring that training and testing are directly correlated. What’s more, the joint FAA-industry committee will periodically review and update ACS standards to ensure it is in line with mechanic knowledge and skill requirements as technology evolves. And, under a new rule allowing for competency-based programs, AMTS can focus on ensuring a student can demonstrate required knowledge, skills and attitudes (as defined in the ACS!), instead of required training hours.
ATEC Treasurer and Embry-Riddle Aeronautical University Associate Professor and Department Chairman Chuck Horning has volunteered hundreds of hours to help usher through the new generation of regulations and standards, “We have an incredible opportunity right now that probably won’t happen again. We started this initiative hoping for a rule change and never dreamed we would have the opportunity to improve the testing process. Now we have the chance to do both and have all the pieces of the puzzle fit like they should.”
ATEC will continue to engage with the agency and congressional leaders to support timely promulgation and smooth implementation. The council will also ensure its member schools have the tools and resources required for a successful transition; webinars, curriculum guides, tools and resources are in development. Take advantage of all ATEC has to offer, and support the council's workforce development efforts, by ensuring your membership is current.
As part of its efforts to support the impending part 147 rulemaking, the FAA requested that ATEC facilitate a short survey of all current part 147 aviation maintenance technician schools. The survey addressed three areas: 1) the design of competency-based programs; 2) the implementation of competency-based programs; and 3) the extension of course offerings through dual enrollment programs.
Sixty two of the 175 certificated schools responded. Of those, 61% stated they would implement a competency-based program if allowed under the new regulation (22% were unsure and 16% said they would not utilize competency-based curriculum).
When asked whether their school would offer courses away from the fixed location (e.g., as part of a high school dual-enrollment program), 66% responded in the affirmative, including 8% that already have some form of dual-enrollment program.
Responses provided strong indication that these opportunities would increase student enrollment.
The data will support an economic analysis that is expected to accompany the final rule.
ATEC Provides FAA Recommendations for AMTS additional fixed locations to support dual enrollment programs
After conducting an FAA-requested survey to support the part 147 rulemaking, ATEC provided additional comment on how the agency may facilitate additional fixed locations for certificated aviation maintenance technician schools.
AMTS are facing unprecedented demand for A&P graduates, to meet the growing need schools are looking at innovative ways to increase enrollment. Dual enrollment programs, whereby AMTS provide course instruction at local high schools, allowing students to earn credit towards an A&P program, are growing in popularity as a solution to the problem.
While the current regulation does not prohibit AMTS from providing courses at another location, local inspector opinion on programs allowable under the regulation varies considerably, with some expressly forbidding the practice. Local office personnel that prohibit dual enrollment generally cite language in FAA Advisory Circular 147-3B, which states that an AMTS “may not operate as a satellite facility” and that “all AMTS must be FAA-certificated as separate facilities.”
Notwithstanding the fact that an AC cannot impose requirements or prohibitions, ATEC beseeched the agency to carefully consider any regulatory language (i.e., satellites vs. fixed locations) that might create confusion in enforcement. It also suggested that the agency utilize current OpSpecs standard templates to introduce additional fixed locations—OpSpecs paragraph A101—and course work provided at those locations—OpSpecs paragraph D100. Keeping in line with standard practice for other air agencies that hold OpSpecs (as opposed to training specifications), the additional locations would be under the control of the AMTS primary location and subject to FAA oversight.
As part of the Council's annual fly-in, aviation maintenance technician school (AMTS) representatives met with FAA officials to discuss several regulatory matters of importance to ATEC's membership. Agenda topics included the agency's reluctance to support AMTS-high school partnerships, the shortage designated mechanic examiners and the need for a part 147 regulation that would allow AMTS to develop competency-based programs.
While the agency could not discuss the pending part 147 regulation given ex parte limitations (a summary of the meeting will be provided to the docket for public inspection), officials listened as attendees spoke on the benefits of a competency-base rule that would provide AMTS the opportunity to meet agency testing standards free from prescriptive requirements (seat time, subject requirements, etc.).
Participants pointed out that competency-based systems are widely-supported by the education community including the Department of Education, and are proven to provide efficient and effective educational programs. Removing prescriptive requirements from the proposed rule would also be in line with the agency’s efforts to implement risk-based oversight. That is, given the low-risk associated with AMTS, FAA resources currently utilized to enforce regulatory requirements such as grading systems, seat time, availability of missed material, etc., could be better utilized in higher risk areas. Further, AMTS operations and the manner in which it educates its students are better overseen by Department of Education and accreditors.
Industry representatives also addressed the agency's concern in the local inspector’s ability to enforce a competency-based rule and measure the effectiveness of its program. AMTS representatives pointed out that the current rule does not provide the framework to measure program effectiveness (i.e., inspector checklists are focused on attendance records and grading policies), and that the AMTS “effectiveness” would ultimately be measured through the mechanic test, which the FAA controls. Ultimately, the agency will only issue a mechanic certificate to those applicants that possess the requisite skill and knowledge, as provided for in the written, oral and practical tests.
Industry representatives also discussed the development of new airman certification standards (ACS) and how those standards should be utilized in the final rule. Once the ACS is developed, the standards could be incorporated into an AMTS operations specifications, to include specific objectives and teaching levels as needed. That way the AMTS would be “required” (through op specs) to teach those items provided for in the mechanic test.
In closing, industry asked the agency to duly consider the benefits of allowing AMTS to implement modern educational systems that other industries have long utilized. They asked agency representatives to permit programs that transition away from seat time in favor of a structure that creates flexibility, and allows students to progress as they demonstrate mastery of subject matter, regardless of time, place, or pace of learning. This type of rule would encourage free-flow of A&P mechanic applicants to an industry that desperately needs a competent and qualified workforce to support continued operations.
ATEC will continue to engage on this topic in anticipation of the new part 147, expected to be issued in the summer of 2017.
In response to an FAA inquiry regarding ATEC's request for a competency-based part 147 regulation, ATEC submitted supplemental comments to the part 147 notice of proposed rulemaking.
Redefining the use of time is the single most significant policy enabler for competency-based learning models; ATEC therefore reiterated its request that the agency remove all prescriptive requirements from part 147, which would allow AMTS to incorporate competency-based learning models into their programs. The supplemental comments also gave specific examples on how AMTS programs could change under a competency-based regulation, and relieve FAA of burdensome and unnecessary oversight responsibilities.
The comments supplement ATEC’s previous comments to the NPRM, and an aviation industry coalition letter and STEM coalition letter in support of those comments.
On Feb. 22, the STEM Education Coalition, an alliance of more than 500 business, education and professional organizations, submitted comments to the FAA part 147 notice of proposed rulemaking (NPRM). In its letter, the group expressed its support for a maintenance technician competency-based learning system that allows industry to freely meet already-mandated knowledge, skill and experience standards.
The coalition’s comments echoed ATEC’s concerns that the NPRM goes beyond the FAA’s basic mandate to oversee and regulate safety in the aviation industry and that educational oversight is a responsibility best left to other executive branch agencies, stating in part: “Our Coalition supports education policies that are flexible and responsive to the needs of the global economy. As proposed in the NPRM, FAA mandates on teaching times, passing norms, maximum levels of instruction, student/teacher ratios, and static curriculum topics are not hallmarks of a modern, competency-based structure that industry desperately needs. These requirements lead to waste and increased costs for industry and students pursuing a STEM education.”
As a member of the coalition’s leadership council, ATEC furthers the group’s mission to educate government about the impact STEM education has on the global economy and to ensure student success in technical fields. Learn more about the coalition’s good work at the April 9-12 annual conference in Atlanta, or at http://www.stemedcoalition.org/.
On Feb. 1, ATEC led a broad effort to get the new part 147 right. The council submitted comments to the FAA’s notice of proposed rulemaking (NPRM) and organized an industry-wide effort to demand a competency-based rule.
ATEC’s comments, developed by a working group of AMTS representatives, provided a roadmap that would allow institutions to tailor their programs while adhering to agency standards. “Industry has suffered the repercussions of an outdated rule for far too long,” the comments said. “[Aviation maintenance technician school] students have been forced to spend wasted effort and time learning antiquated skills, and industry has borne the cost. We desperately need a competency-based rule that gives educators flexibility to teach the future workforce the skills needed to support the ever-changing, technology-driven, dynamic aviation industry.” The comments also provided specific regulatory language to aid swift issuance of a final rule.
To further highlight the need for a competency-based rule, ATEC sought assistance from its industry allies. In a separate submission, 14 organizations decried the NPRM’s continued reliance on class time at the expense of technical capability.
“Put simply, the proposal would impose 20th century educational practices on a 21st century industry,” the group, which included Airlines for America, the Aeronautical Repair Station Association and a broad swath of aviation, maintenance and educational interests, said. “It maintains its predecessor’s antiquated concern with the time a student spends in a classroom seat rather than focusing on the skills he or she actually gains. A competency-based standard, free of defined schedules and specific hour requirements, will allow industry to transition away from seat time in favor of a structure that creates flexibility and allows students to progress as they demonstrate mastery of subject matter, regardless of time, place, or pace of learning.”
While part 147 is the regulatory foundation for ATEC’s member institutions, the council- led effort serves a larger purpose. As its allies have recognized, getting the AMTS rule right means effective schools, competent students and a flourishing aviation community.
Stay tuned as ATEC continues to push for an efficient rulemaking process that culminates in the best possible rule.
To view the council’s comments, click here.
To view the combined industry comments, click here.
ATEC officially enlisted Congress in the council’s effort to update 14 CFR part 147. After weeks of development, Representatives Tom Rice (S.C.) and Jim Bridenstine (Okla.) sent a letter asking the FAA to make the rulemaking its highest priority.
To ensure a final rule is issued efficiently, the letter emphasized that the “outdated part 147 mandates hinder the aviation maintenance industry's ability to compete and grow” and encouraged the agency to “continue on the course identified in the Notice of Proposed Rulemaking.”
The effort to produce a final rule updating 147 is a top priority for ATEC. Stay tuned as the council continues to use every avenue to improve AMTS’s regulatory foundation.
February 2, 2016 update: Administrator Huerta responds to the congressional letter, stating in part "The part 147 rulemaking is among the highest priorities for the FAA. We are committed to delivering regulation that encompasses new technology and remains flexible to grow and adapt with the industry... The FAA will proceed with this rulemaking as timely and efficiently as possible while adhering to the requirements of the Administrative Procedures Act."
The part 147 rulemaking working group continues to develop ATEC’s comments to the aviation maintenance technician school notice of proposed rulemaking (NPRM) (see previous stories here, here, here and here). The working group will solicit member feedback on the proposed rule, giving the council time to finalize and gather industry group support before submission. Comments to the NPRM are due Feb. 1, 2016.
The part 147 rulemaking working group continues to develop ATEC’s comments to the proposed part 147 rule (see previous stories here, here and here). Thank you to the following industry volunteers who are giving their time to the cause--
On Nov. 19, the Federal Register published the FAA's intention to extend the comment period for its proposed update to 14 CFR part 147. The move came in response to a request from 14 aviation and education groups, led by ATEC, submitted in late October.
"[The final rule will impact] not only the hundreds of institutions that educate our workforce, but also the thousands of businesses that rely on AMTS graduates to keep aircraft in flight," the coalition explained in its extension request. "With the additional time requested, the aviation industry and its partners in technical education will help the agency develop a rule that supports schools, aids students at the beginning of a rewarding career and serves an important and growing industry."
Comments are now due by Feb. 1, 2016. While the agency opted against providing the 90 additional days requested by the aviation community and its technical education allies, AMTS must fully utilize the time available to ensure robust guidance is provided to regulators.
Now that the deadline is set, the council and its allies can focus on substantive comments. Members are encouraged to review the proposal (see ATEC's side-by-side comparison) and submit feedback to email@example.com.
ATEC Member Alerts
Stay tuned for updates on everything ATEC members need to know as well as ways that you can help the council and the AMTS community.