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.
On Sept. 20, an aviation coalition continued its push to solve the aviation maintenance workforce crisis by helping the government to define it. The group, spearheaded by ATEC, filed comments asking the Standard Occupational Classification Policy Committee to revise aviation maintenance personnel definitions to more accurately reflect the aviation maintenance industry.
The SOC system is the source of all federal occupational statistics; it determines precisely which occupations exist and is used by government agencies to calculate and analyze wages and employment trends, supply and demand, and expected growth. 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”, with a separate category for “Avionics Technicians”.
The alliance, including the Aeronautical Repair Station Association, the Aerospace Maintenance Council, Airlines for America, the Aviation Technician Education Council, the Cargo Airline Association, the General Aviation Manufacturers Association, Helicopter Association International, the National Air Transportation Association, a former member of the National Transportation Safety Board and the Regional Airline Association, asked that the two categories be replaced with three occupations: certificated mechanics, certificated repairmen and non-certificated technicians. The coalition argued that 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.
For AMTS, a change in the classification structure would mean more precise wage and outlook information to help recruit potential A&P mechanics. Currently, federal occupational data for Aircraft Mechanics and Service Technicians and Avionics Technicians does not take into consideration whether the person has an A&P license. Theoretically, a change in the structure would reflect a higher starting pay for those with a mechanic certificate (as opposed to aviation technician positions that do not hold a certificate).
Reclassification, along with other planned improvements to the Department of Labor’s analysis tools, would also positively influence the “industry outlook” for aviation mechanics, which, according to O*NET OnLine, does not include rapid growth or a large number of job openings. A “bright outlook” categorization often determines whether a career counselor will recommend a career path, making the designation extremely important for the future aviation workforce.
ATEC looks forward to working with our industry partners and government agencies to ensure the future of aviation maintenance is properly reflected as shiny and bright.
As part of the airman certification standards (ACS) development, the FAA's newly-created Aviation Exam Board (AEB) will be reviewing each question in the knowledge test bank. Its first round of edits will address the "low handing fruit"; that is, questions that should be removed from the bank entirely.
Through the ACS working group, the FAA is requesting feedback on the current general knowledge sample exam. Comments will be considered as the AEB begins their work to review and update the the knowledge test bank.
ATEC will compile all feedback received from the membership for consideration by the AEB. Member comment is due to email@example.com by Oct. 6.
An FAA and industry working group continues development of the aviation maintenance technician airman certification standard, which will set the framework moving forward for the written, oral and practical A&P mechanic test. The initial draft combining general, airframe and powerplant is available for download here. Member comment is due to firstname.lastname@example.org by Oct. 6.
The ACS is fundamentally an enhanced version of the practical test standards (PTS), with the addition of knowledge and risk management elements to each subject area. The result is a comprehensive document that outlines what an applicant needs to know, consider, and do in order to pass both the knowledge and practical tests for a mechanic certificate.
The timing of ACS development and part 147 rulemaking activities gives our community a unique opportunity to ensure teaching requirements are in line with mechanic testing standards. ATEC will continue to request that AMTS have the ability to teach to that standard free of prescriptive requirements and defined subject areas. The ACS would naturally be the basis and framework for every AMTS teaching curriculum, which is why it’s so important that the AMTS community participate in its development.
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