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.
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.