ATEC Fly-In News: FAA Updates Attendees On Key Projects

The council's annual Fly-In packs a significant amount of regulatory and legislative business into its focused, two-day format. Among the growing annual traditions is an update from FAA officials on rules, guidance, and other action items that affect aviation maintenance technician schools (AMTS)--and this year was no exception.

In addition to a detailed update on the comprehensive re-write of Advisory Circular 43.13-1B (https://www.atec-amt.org/news/atec-fly-in-news-faa-provides-update-on-4313-1b-revisions), FAA officials touched on a number of other projects. A general theme is that changes by the Administration have caused many rulemakings and FAA-sponsored committee work- to slow considerably.

Earlier this year, the Dept of Transportation terminated members of the Aviation Rulemaking Advisory Committee (ARAC), subcommittees, and working groups. Their work is instrumental--and in some cases mandated by Congress--in shaping major rules and guidance. While a dormant ARAC does not stop all work on affected projects, it stretches them out, making timelines difficult to meet.

Some specific updates:

• Airmen Certification Standards (ACS) and handbook development has stalled due to the ARAC (and related ASC working group) pause. The FAA and industry--including the council, which participates in several affected ARAC working groups--are pressing forward to further initiatives where they can, but are not meeting regularly as a working group to finalize recommendations to standards and handbooks. ATEC continues to work with industry stakeholders to develop recommended changes and will provide those to the agency outside the working group if necessary.
• Organization Designation Authorization (ODA) expansion to include airmen certification functions--a key step in alleviating pressure in the mechanic testing pipeline (https://www.atec-amt.org/news/atec-submits-comments-in-support-of-testing-designation-expansion-to-organizations)-- is progressing. Final guidance--FAA Order 8100.15C--is undergoing legal review and is expected to be released "imminently."
• Several reauthorization initiatives are also on hold while ARAC is restaffed. Tasked by Section 405 of the 2024 FAA Reauthorization Act, the group is recommending early knowledge testing eligibility for mechanic applicants. Kevin Morgan, Airmen Section Manager, Airman and Special Programs Group, said the FAA will seek industry input on what type of certification and related working privileges could be granted upon passing the written test. "Let's call it similar to a student pilot--you have a student mechanic certificate," Morgan said. "What can you do with that? With a student pilot certificate, you can go fly with an instructor...what can you do with [a maintenance equivalent]? These are the things we are pondering internally."
• Helping military-trained mechanics transition to civilian roles, Sec. 426 of the 2024 FAA act is also held up, albeit indirectly by the stalled ARAC process. The law orders the FAA to issue a new rule, but does not require direct ARAC participation. The language does, however, order the FAA to consider "any applicable recommendations" from the ARAC airman certification working group. "We definitely want to hear back from the ARAC, so that's going to be on hold until the ARAC is back up and running."
• Updates to part 65 guidance are coming soon, said Tanya Glines, Aviation Safety Inspector, Airmen and Special Programs Group, incorporating the new records falsification rulemaking that becomes effective in November.
• Glines also provided insight into the evolving part 147 AMTS certification process. Guidance issued in January (Notice 8900.728 - Determine Applicant Readiness for Certification) updated the standards that all certificate applicants--not just prospective part 147 schools--must meet before the agency will begin processing applications. The goal is to ensure an applicant has everything needed--documentation, manuals, etc.--to begin the initial certification process. This allows the agency to prioritize its resources, streamline approvals, and minimize applicant wait times. The FAA has 13 part 147 applications in process and 12 more on the waiting list.

ATEC is either directly involved in or closely monitoring each of these issues and will provide updates as warranted.