On June 4, a coalition of aviation trade associations took the first step towards solving the aviation maintenance workforce crisis by helping the government to define it. The group, spearheaded by ATEC, asked the Standard Occupational Classification (SOC) Policy Committee and the Office of Management and Budget (OMB) to revise the SOC system to more accurately reflect the aviation maintenance industry.

A broad alliance, including the Aeronautical Repair Station Association, the Aerospace Maintenance Council, Airlines for America, the Cargo Airline Association, the General Aviation Manufacturers Association, the National Air Carrier Association, the National Air Transport Association,  the Regional Airline Association and a Former Member of the National Transportation Safety Board, joined ATEC in submitting comments to the SOC revision process, the results of which are set for implementation in 2018.

The SOC system provides the framework for all occupational statistics collected and disseminated by federal agencies. For federal statistical purposes, it determines precisely which occupations exist and has a significant impact on the legislators, educators, employers and job seekers who utilize that data. The aviation maintenance industry has been stuck in a void – trapped under incorrect classifications – for years. Within the current system, nearly all aviation maintenance professionals are classified into a single occupation titled “Aircraft Mechanics and Technicians.”

The group requested that this lone category be replaced with three separate occupations: certificated mechanics, certificated repairmen and non-certificated technicians. Classifying workers using FAA certification is the most logical and useful method; since aviation safety rules use the same definitions to dictate precisely who is allowed to perform maintenance, preventive maintenance and alteration tasks.

Along with a requested clarification of the “Transportation Inspectors” category, the submission proposed elimination of “Avionics Technicians” as a distinct category. These professionals should be tracked based upon certification, ATEC and its allies contend, just like every other aviation maintenance worker.

“Data empowers organizations to make sound decisions,” says Ryan Goertzen, ATEC President, “With Today's SOC structure we can't build a world class work force because the data is unreliable and inaccurate to capture our industry needs.”

The rules governing AMTS are long-overdue for an overhaul; there has been no serious update to 14 CFR part 147 since the 1970s. You can help get regulators to re-write it by providing real-world examples of its age.

In order to make the problem resonate on Capitol Hill and convince Congress to demand action from the FAA, the council needs to be able to illustrate how out-of-date part 147 has become. To do this, ATEC needs your help: Tell us how the existing regulation is an obstacle to world-class training. While any example is helpful, the effort would particularly benefit from those that make a clear point even to members with no aviation experience.

For example: It has been so long since part 147 was re-written that students are still taught the same techniques required to construct and maintain the Wright Flyer.

Submit your examples to Communications Manager Brett Levanto (brett.levanto@atec-amt.org) as soon as possible.

On April 14, the ATEC Board of Directors held its second-quarter meeting in conjunction with the annual conference in Orlando.

The board adopted a new set of bylaws that will provide the guidance and structure needed to ensure the council continues to grow and develop. The bylaws, along with board meeting minutes and approved council budgets, are available on ATEC’s governance webpage: www.atec-amt.org/governance

At the meeting, directors also appointed two industry member representatives to additional one-year terms: AMTSociety Executive Director Ron Donner and Premier Aircraft Sales, Inc. Vice President Art Spengler.

Two institutional director terms expired; the board would like to officially thank and recognize Hallmark College of Aeronautics Senior Vice President of University Operations Jay Gregson and Western Michigan University College of Aviation Professor Kevin High, for their service on the Board of Directors over the last year. We expect and look forward to their continued engagement in council and board activities in the coming years.

The current board of directors listing is available at www.atec-amt.org/board-members.

Moving forward, a special committee of director and member representatives will solicit nominations for open director positions. Stay tuned for more information on that process and to learn about director qualifications and obligations.

On June 5, 2015, the FAA issued Advisory Circular 147-3B, Certification and Operation of Aviation Maintenance Technician Schools.

The revision incorporates many of the council’s suggestions provided in its comments on the draft AC (see previous member alert), including a rewrite of the distance learning appendix. The agency was not as receptive to ATEC’s suggestions on “makeup work” provisions or streamlining question & answer content.

Unlike the recent revision to Order 8900.1 (see member alert), the guidance material does not include language that would limit distance learning curriculum to 400 hours.

FAA Order 8900.1, the Flight Standards Information Management System (affectionately referred to as “FSIMS,” pronounced “FIZZ-ims”) was recently revised to provide aviation safety inspectors guidance on certifying and evaluating part 147 certificated aviation maintenance technician schools (AMTS).

The changes to Vol. 2, Ch. 12, Section 1 and Section 3 include the addition of a “certification process flowchart” and instructions on issuing operations specifications. Most notable for current AMTS, the revision incorporates inspector guidance for approving distance education curriculum and ensuring the availability of missed material.

The inspector guidance seeks to limit distance learning instruction to 400 hours. The council maintains – as it did in its comments to draft Advisory Circular (AC) 147-3B – that distance learning instruction should not be limited to hours, rather by the subject matter and material and technology available to ensure the knowledge is properly conveyed.

Thanks to the efforts of Blue Ridge Community College instructor and ATEC director Fred Dyen, representatives at the FAA’s aircraft maintenance division have confirmed that the 400 hour “requirement” was inadvertently included and is scheduled for removal in the order’s next editorial update.

Also of concern is inspector guidance for implementation of § 147.31(e), which requires that the AMTS system “show hours of absence allowed and how missed material will be made available to the student.” The order’s language goes beyond the scope of the regulation, specifically “requiring” that all missed projects and assignments be “made up” and the manner in which that must be accomplished.

Orders are meant to provide direction to FAA employees, and not the public at large (see ATEC’s member alert on updates to Order 8900.2). However, when an inspector feels compelled to act in a particular way because of direction in “the handbook”, that decision has real practical effect to those subject to FAA regulation. ATEC maintains that additional regulatory requirements imposed through a non-legislative rule (such as an order) should be promulgated in accordance with the procedural requirements of the Administrative Procedures Act, which allow for public notice and opportunity to comment; otherwise it has no legal effect.

While many of the Order changes address initial certification, much of the criteria is applicable to currently-certificated entities. AMTS personnel should therefore ensure a proper and thorough review of the revised sections. Please send any additional comments or observations regarding the revision to atec@atec-amt.org for inclusion in the council’s letter to the FAA addressing these concerns.

Beginning September 30, 2015, FAA inspectors will utilize revised guidance to enforce regulations found in Order 8900.2A governing Designated Mechanic Examiner (DME) appointments and A&P exams. The Order revises DME appointment qualifications and various aspects of the practical test standards (PTS).

Notable changes to Order 8900.2 include:

• Prohibiting DMEs from examining more than one applicant at a time (Ch. 5, ¶ 2(k)).
  
• Requiring AMTS instructors seeking appointment as a DME to have been an instructor for the past five years and to have concurrently exercised the privileges of a part 65 certificate for three years (Ch. 6, ¶ 1(a)(3)(d)).
  
• Increasing the difficulty of the of the exam by reducing the maximum number of questions per subject area from ten to seven (Ch. 6, ¶ 10(a)(1)(a)).
  
• Requiring reexamination of the entire oral/practical exam upon a student’s failure of a single subject area. (Ch. 6, ¶ 11(a) Notes).

Orders are meant to provide direction to FAA employees, not the public at large. However, when agency personnel are compelled to act in a particular way because of internal guidance, the agency is able to circumvent the rulemaking process and impose burdens on industry without notice or public comment. ATEC is working diligently with members to submit a formal letter to the agency objecting to the changes and manner in which they are “imposed.” 

Stay tuned...

Also see ATEC's member alert on updates to Order 8900.1.