Part 147 Rulemaking
WHERE ARE WE NOW? |
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For the latest news, visit www.atec-amt.org/news/category/part-147
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.
Given new testing standards and the timing of a new part 147, the ACS working group made a formal recommendation that the FAA 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.
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.
In September 2017, the FAA announced its intention to issue a Supplemental Notice of Proposed Rulemaking (SNPRM) 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.
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.
Given new testing standards and the timing of a new part 147, the ACS working group made a formal recommendation that the FAA 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.
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.
In September 2017, the FAA announced its intention to issue a Supplemental Notice of Proposed Rulemaking (SNPRM) 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.
RECENT ACTIVITIES AND RESOURCES |
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- Sept. 15, 2017: Sen. Hatch (UT) requests update on status of supplemental rulemaking.
- Sept. 4, 2017: FAA announces it will issue a supplemental notice of proposed rulemaking.
- Aug. 22, 2017: Rep. Gus Bilirakis (FL-12) joins colleagues asking for an update on promulgation of part 147.
- Aug. 21, 2017: ATEC provides online webinar, Part 147: Where Are We Now? (Recorded version available for members).
- Aug. 7, 2017: ATEC pens editorial in TheHill.com highlighting the issue and initiating grassroots efforts.
- Aug. 2, 2017: Rep. Lamar Smith (TX-21) sends congressional inquiry asking for an update on rulemaking efforts.
- June 28, 2017: ACS working group makes formal recommendation to ensure the new part 147 takes into account the ACS, and ensures that training and testing are correlated.
- May 29, 2017: ATEC facilitates FAA-requested survey of AMTS to support agency economic analysis for rulemaking.
- May 18, 2017: ATEC submits recommendation for utilization of AMTS fixed locations to support dual enrollment programs.
- Sept. 9, 2016: ATEC holds face-to-face meeting to provide further information in support of a competency-based rule.
- May 17, 2016: ATEC submits supplemental comments supporting a competency-based part 147 regulation.
- Feb. 22, 2016: The STEM Education Coalition, an alliance of more than 500 business, education and professional organizations, submitted comments to the part 147 notice of proposed rulemaking in support of ATEC's efforts.
- Feb. 12, 2016: FAA Administrator Huerta responds to congressional letter stating that part 147 "is among the highest priority".
- Feb. 1, 2016: ATEC submits comments to part 147 NPRM. In a separate submission, 14 organizations decried the NPRM’s continued reliance on class time at the expense of technical capability.
- Jan. 13, 2016: Congressional leaders, prompted by ATEC, send letter to FAA calling for swift action on part 147 rulemaking.
- Nov. 19, 2015: FAA issues notice of proposed rulemaking for part 147.
- Jan. 8, 2009: Industry working group recommended broad changes to the current part 147.
