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.
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