Fourteen trade associations submitted joint comments to the part 147 supplemental notice of proposed rulemaking, delivering a powerful message of unity and support for technician education.
The coalition echoed comments previously submitted by ATEC, asking the agency to reconsider prescriptive terms, and pushing for an outcomes-based approach to regulatory oversight. The group reiterated the need for a simplified approach to dual enrollment programs and deference to Department of Education requirements for matters concerning the quality of education.
"Fixing 147 is an industry imperative," the letter said. "Handicapping our schools burdens both graduates and employers. Give us the flexible and dynamic rule needed to ensure we can educate the future workforce by the best means necessary."
In addition to ATEC, the following organizations signed the letter:
Accrediting Commission of Career Schools and Colleges
Aeronautical Repair Station Association
Aerospace Maintenance Council
Aircraft Mechanics Fraternal Association
Aircraft Owners & Pilots Association
Airlines for America®
Cargo Airline Association
International Air Transport Association
National Air Carrier Association
National Air Transportation Association
National Business Aviation Association
Professional Aviation Maintenance Association
Regional Airline Association
Read the joint comments here: www.regulations.gov/document?D=FAA-2015-3901-0132.
In a June 12 submission, ATEC voiced its feedback to the latest FAA rulemaking regarding aviation maintenance technician schools.
The comments, a committee-run work product that took three months and more than ten conference calls to create, push back on what the council says would create an overly-prescriptive system and stifle an already inadequate mechanic pipeline.
The submission calls for FAA deference in all matters concerning the quality of education, an element that falls squarely in the Department of Education's (ED) purview. As further explained in the comments, "Higher institutions of learning are overseen by accreditors that ensure educational outcomes are achieved through annual audits and regular oversight. The agency’s proposals duplicate—and often contradict—these accreditation requirements."
The council also reiterated it's plea for an outcomes-based approach, one that would utilize new mechanic airman certification standards as the basis for curriculum, and negate the need for the agency to micromanage schools through curriculum approvals and hour requirements.
Finally, the council offered an alternative to the satellite system proposal set forth in the supplement. It suggests a simplified approach that would allow AMTS to include "additional fixed locations" on their operations specs, consistent with processes for other air agencies. The familiar scheme would allow schools to provide content at local high schools and support dual enrollment programs, so long as the "additional fixed location" met the requirements of part 147. Indeed, as the council stated in its comments, the agency could implement this opportunity even before a formal rule change.
Read the council's comments in their entirety by clicking on the button below.
ATEC Provides FAA Recommendations for AMTS additional fixed locations to support dual enrollment programs
After conducting an FAA-requested survey to support the part 147 rulemaking, ATEC provided additional comment on how the agency may facilitate additional fixed locations for certificated aviation maintenance technician schools.
AMTS are facing unprecedented demand for A&P graduates, to meet the growing need schools are looking at innovative ways to increase enrollment. Dual enrollment programs, whereby AMTS provide course instruction at local high schools, allowing students to earn credit towards an A&P program, are growing in popularity as a solution to the problem.
While the current regulation does not prohibit AMTS from providing courses at another location, local inspector opinion on programs allowable under the regulation varies considerably, with some expressly forbidding the practice. Local office personnel that prohibit dual enrollment generally cite language in FAA Advisory Circular 147-3B, which states that an AMTS “may not operate as a satellite facility” and that “all AMTS must be FAA-certificated as separate facilities.”
Notwithstanding the fact that an AC cannot impose requirements or prohibitions, ATEC beseeched the agency to carefully consider any regulatory language (i.e., satellites vs. fixed locations) that might create confusion in enforcement. It also suggested that the agency utilize current OpSpecs standard templates to introduce additional fixed locations—OpSpecs paragraph A101—and course work provided at those locations—OpSpecs paragraph D100. Keeping in line with standard practice for other air agencies that hold OpSpecs (as opposed to training specifications), the additional locations would be under the control of the AMTS primary location and subject to FAA oversight.
Stay tuned for updates on everything ATEC members need to know as well as ways that you can help the council and the AMTS community.