ATEC Asks FAA for Regulatory Framework to Support High School Dual Enrollment Programs

Note: The following text is largely based on an Aviation Week Network article, scheduled to publish in October’s edition of InsideMRO.

A recent ATEC initiative asks the FAA to provide a better framework for aviation maintenance programs looking to expand their reach into high schools.

ATEC’s Pipeline Report estimates that certificated Aviation Maintenance Technician Schools (AMTS) need to increase production by 30% to meet projected industry demand for certificated mechanics over the next 20 years. Unfortunately, FAA data indicates that AMTS enrollments are shrinking, not growing. Nationally, A&P student populations have decreased 2% since 2014.

One increasingly popular strategy to increase enrollment and program awareness is through the development of high school partnerships, whereby high school students can begin mechanic coursework earlier in their educational careers.

According to a 2017 ATEC survey, 8% of AMTS have high school dual enrollment programs. In most cases, the high school students are bused onto the AMTS campus to complete the coursework. Or, the AMTS will award credit for “previous experience” (allowable under § 147.31(c)) for students that enroll in the A&P program after high school graduation.

Out of the 62 respondents (representing 36% of all AMTS), 66% said that if the FAA regulation provided a better pathway for dual enrollment programs, they would be more likely to initiate such a program.

In a Sept. 6 letter to the FAA, ATEC called on the agency to make policy changes that would allow schools to deliver AMTS content to enrolled students away from its “primary location,” via “additional fixed locations” provided on the AMTS operations specification. Under the proposal, a part 147 certificated school could provide its curriculum at a partner high school and bestow upon that high school student AMTS credit without that student first enrolling in the A&P program. Since the high school is provided as an “additional fixed location” on the part 147 operations specifications, that location would also be subject to FAA oversight.

While the regulation does not prohibit AMTS from providing coursework at another location, FAA “endorsement” of the practice varies across local offices, with some officials expressly forbidding it. Local inspectors prohibiting the AMTS from providing content “away from the fixed location” often cite FAA guidance material that says schools may not “operate a satellite facility” and that “all AMTS must be FAA-certificated as separate facilities.” Notwithstanding the fact that guidance cannot impose requirements or prohibitions, it is safe to say that the language has discouraged the proliferation of dual enrollment programs.

The FAA recognized the issue in its recent part 147 supplemental notice of proposed rulemaking, offering regulatory language that would provide for the approval of “satellite facilities.” ATEC maintains that the proposal is overly cumbersome and would unnecessarily create a new set of approvals that would dissuade many AMTS from utilizing the proffered solution (see related story). Its recent letter proposes the alternative approach.

ATEC discussed the proposal in detail during the FAA roundtable at the Washington Fly-in earlier this month. It is standing by for the FAA’s formal response to its request.

Download the letter