ATEC Joins Working Group to Encourage FAA Publication of Delayed Airman Certification Standards2/24/2021 In 2016, the FAA published its first airman certification standards (ACS) under the watchful eye of the FAA Aviation Rulemaking Advisory Committee's Airman Certification System Working Group. The purpose of the ACS is to set forth what an airman applicant must know, say, and do in order to qualify for certification, and act as the bedrock on which FAA testing and guidance materials are based. Since the original ACS was published, six others have followed, all providing knowledge and skill standards for pilot certification.
In 2019, the aviation maintenance community was invited to participate in the the agency's development of the Mechanic Airman Certification Standard. Since that time, ATEC has been steadfast in its continual review and comment on the draft standard, with the understanding that those standards when published would ultimately drive training and curriculum development. Unfortunately, while the draft ACS is near completion, it has joined eleven other ACS in a long line of documents awaiting publication. The backlog is due to a seeming reinterpretation of the FAA's responsibilities with regard to standards publication. Due to the administration's response to promulgation of a Department of Transportation rulemaking, in 2019, the working group's efforts were brought to a halt. On Feb. 23, the ACS working group sent a letter, signed by several members of the ATEC community including its executive director Crystal Maguire, urging the agency to publish the long-awaited standards. In its ask, working group members provided a potential solution that would ensure the ACS remains a living, breathing document with the flexibility to adapt testing and training as aviation technologies continue to evolve: "We submit for your consideration that the ACS is not subject to Title 49 Code of Federal Regulations (CFR) part 5 administrative procedures," said working group members. "A common sense approach is that the ACS should not be considered rulemaking or guidance, but instead a framework for internal agency governance of certification processes. Industry will in turn incorporate the ACS knowledge and skill elements in its own training programs because it knows the agency will assess those elements in its FAA-facilitated airman tests." Publication of the ACS is vital to the aviation education community given an expected interim final rule will require FAA-certificated A&P schools align their curriculums with the ACS. The same week the ACS working group delivered its letter encouraging quick publication of the backlog of ACS, ATEC also sent a letter to FAA officials outlining its expectations with regard to the new part 147 and how it should incorporate those standards (see related story).
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This month, the FAA notified the public of changes made to the written test bank (as further explained in revised sample exams and the latest "what's new" document).
The FAA, in collaboration with industry representatives, are currently reviewing the knowledge test bank to ensure correlation with imminent Mechanic Airman Certification Standards. Through an exam review board "boarding" process, some questions in the test bank have been edited, removed, or archived. Aviation Supplies and Academics, Inc. (ASA) publishes specific changes made to sample exams for each test roll. That analysis can be found at www.asa2fly.com/FAA-Knowledge-Exams-W22C162.aspx. The council continues to work through the ACS working group to ensure a documented and transparent process for creating, vetting and revising test bank questions. The FAA is currently utilizing the ACS to review and edit the test bank. ATEC Treasurer and Embry-Riddle University Aviation Maintenance Science Department Chairman Chuck Horning is the industry representative on that review board. Members are encouraged to provide feedback on student experiences while the test bank undergoes revision to coincide with the new ACS. Send comments to atec@atec-amt.org. The next FAA test change is expected in January 2020. When the FAA Reauthorization Bill H.R. 302 is signed into law, ATEC and its industry allies will have successfully secured a congressional mandate for a fast-tracked new part 147.
The directive in section 624 of the reauthorization bill currently reads: (a) REGULATIONS.—Not later than 180 days after the date of enactment of this Act, the Administrator of the Federal Aviation Administration shall issue a final rule to modernize training programs at aviation maintenance technician schools governed by part 147 of title 14, Code of Federal Regulations. (b) GUIDANCE.—Not later than 180 days after the date of enactment of this Act, the Administrator shall coordinate with government, educational institutions, labor organizations representing aviation maintenance workers, and businesses to develop and publish guidance or model curricula for aviation maintenance technician schools referred to in subsection (a) to ensure workforce readiness for industry needs, including curricula related to training in avionics, troubleshooting, and other areas of industry needs. (c) REVIEW AND PERIODIC UPDATES.—The Administrator shall-- (1) ensure training programs referred to in subsection (a) are revised and updated in correlation with aviation maintenance technician airman certification standards as necessary to reflect current technology and maintenance practices; and (2) publish updates to the guidance or model curricula required under subsection (b) at least once every 2 years, as necessary, from the date of initial publication. (d) REPORT TO CONGRESS.—If the Administrator does not issue such final rule by the deadline specified in subsection (a), the Administrator shall, not later than 30 days after such deadline, submit to the appropriate committees of Congress a report containing-- (1) an explanation as to why such final rule was not issued by such deadline; and (2) a schedule for issuing such final rule. In November 2015, the FAA issued a part 147 notice of proposed rulemaking. ATEC submitted extensive comments, supported by a coalition of allies, calling for a less-prescriptive rule that would allow for competency-based programs and the freedom to cater training to industry needs. In September 2017, the FAA announced its intention to issue a Supplemental Notice of Proposed Rulemaking (SNPRM), which suggests that the proposed rule had been substantially changed in response to comments received. The public is still awaiting publication of the supplement. Government officials have indicated it will be published by year end. Once the supplement is published, the public will have 2-3 months to comment, and the agency will take some time to adjudicate those comments before issuing a final rule. Given what still needs to be done before a new part 147 is promulgated, it is unlikely that industry will see a new part 147 in six months as the law will direct. However, the congressional directive should ensure that the agency makes the rulemaking a high priority and help fast-track it through the regulatory process. Given the law will also direct the agency to consider imminent mechanic airman certification standards (ACS) for program development; it would behoove program administrators to begin reviewing that draft document with an eye toward curriculum revision (the latest and future revisions of the draft document will be available at www.atec-amt.org/airman-certification-standards). The final ACS is expected to publish in June 2019, with a June 2020 implementation date. The agency will work with industry representatives to revise the document periodically thereafter. Once published, the working group will make recommendation that the ACS not be revised for at least two years to give schools time to adapt to the change. Since it is possible that we will not have a new part 147 before the ACS is published—even with the congressional mandate—schools will need to ensure compliance with the regulation while also adequately preparing A&P grads for the FAA mechanic test, which will be based on the ACS. The legislation also calls for the agency to develop guidance material or model curriculum to aid program development. ATEC expects draft guidance will be issued along with the SNPRM and look forward to making extensive comment to that document to ensure alignment with the ACS. Last summer, the aviation maintenance technician airman certification standards (AMT ACS) working group made recommendation to the FAA that the agency properly consider new testing standards during its development of the new part 147.
The group requested that once static curriculum requirements are removed from part 147, that the agency utilize the AMT ACS as the basis for training curriculum, which would provide standardization across testing and training. It argued that since the AMT ACS will be continually revised and updated, it would be the perfect vehicle to ensure that both training and testing are in line with industry needs as technology evolves. The FAA Aircraft Maintenance Division disagreed, stating that it will instead base curriculum requirements on a 2007 ARAC working group recommendation which envisioned a maintenance training review board (MTRB) to provide ongoing curriculum recommendations and changes. In a subsequent letter (dated March 12 but officially presented at a June Aviaiton Rulemaking Advisory Committee meeting), the working group contends that “reliance on old information to the detriment of new initiatives does a disservice to the industry and all hard-working [volunteers] and agency participants." It asserts that given the subsequent development of the AMT ACS, a separate curriculum standard and governing board is unnecessary and would only enable a greater divide between testing and training. Implementation of new AMT ACS is expected in 2020. The community is awaiting a supplement to the 2015 part 147 notice of proposed rulemaking, anticipated to publish in August. More information on the Airman Certification Standards is here. A timeline and background information on part 147 rulemaking is here. As ATEC members well know, the FAA is in the process of replacing the Aviation Mechanic General, Airframe, and Powerplant Practical Test Standards (PTSs) with a single Aviation Maintenance Technician (AMT) Airman Certification Standard (ACS).
The ACS is an “enhanced” version of the PTS that will connect standards to guidance and test questions, provide a single set of standards for the AMT airman knowledge, oral, and practical tests, and tell the applicant, instructor, and evaluator what the FAA expects AMT applicants to know, consider, and do to earn an FAA AMT certificate with Airframe and Powerplant ratings. For now, the AMT PTS (FAA-S-8081-26A, -27A, -28A) remain in effect; and applicants, instructors and evaluators should continue to use the current PTS for the oral and practical tests. The agency published a draft version of the AMT ACS so stakeholders may familiarize themselves with the new document and provide feedback. The final version of the AMT ACS is expected to be effective June 2020. The draft document is available at https://www.faa.gov/training_testing/testing/acs/. Comments are due to afs630comments@faa.gov by May 31, 2018. A June 28, 2017 letter was formally presented at a recent Aviation Rulemaking Advisory Committee (ARAC) meeting, recommending that the FAA ensure part 147 is properly aligned with new airman certification standards.
The recommendation was initiated by the ACS working group, which warned against creating training standards in part 147. The group argues that the ACS should set the minimum knowledge and skill requirements for mechanic certification, as provided for in part 65. Part 147 has essentially set the standard through its curriculum requirements, which is misplaced. The working group communicated these sentiments to AFS-350 through a formal recommendation asking that it 1) revise part 65 to provide the baseline standard for mechanic knowledge and skill requirements, 2) remove any reference to curriculum requirements or subject areas from part 147, 3) reference the AMT ACS in AMTS operations specifications to ensure that training and testing are directly correlated and 4) utilize the ARAC Airman Certification System Working Group as the driver for changes to training requirements. The Aviation Maintenance Technician (AMT) Airman Certification Standards (ACS) will soon replace current practical test standards (PTS), and clearly define minimum knowledge and skill requirements for A&P mechanics. Once completed, the ACS will provide the framework for the written, oral and practical mechanic tests; and subsequently, a guide for revising handbooks, oral questions, practical projects and the knowledge test bank. That means outdated questions and projects will be replaced with relevant assessment material, and incorrect, incomplete or inadequate questions and projects will be updated or removed.
An FAA-industry working group has finalized its initial draft of the document, available at the link below. The draft version will be utilized to "board" all questions in the A&P knowledge test bank. The purpose of the review is to remove, replace or revise outdated or incorrect questions. The process will also provide a "double check" of the draft ACS to ensure all relevant assessment material is addressed in the standard. The FAA invited an industry representative to participate on the test question review board; ATEC Treasurer and Embry-Riddle University Aviation Maintenance Science Department Chairman Chuck Horning has accepted the role. Last month an industry/FAA working group finalized its recommended aviation maintenance technician airman certification standard (ACS). The group provided the final recommendation to agency representatives which will utilize it to "board" knowledge test questions and make further refinement.
ATEC members and stakeholders still have the opportunity to review and comment. The working group expects that further adjustments will be made after the test boarding process. See past member alerts on the ACS for more information about the document and its evolution. The ACS recommendation is available for review here. ATEC hosted a webinar to give its members an overview of the aviation maintenance technician airman certification standard (AMT ACS). The new ACS will provide the infrastructure for the written, oral and practical FAA mechanic tests moving forward. ATEC is taking an active role in its development and is soliciting feedback on the latest version.
The 26-minute webinar is available for download below (the webinar will start at the 30 second mark). The PowerPoint slides are also available here. All are encouraged to listen in to learn about the ACS, it's purpose, implementation, how it will influence the new part 147, and ways to get involved. Comments to the latest version of the ACS are due to ATEC on Thursday, Feb. 16. The next iteration of the aviation maintenance technician airman certification standard (ACS) is available for review and comment, download it here.
Member comment is due by Jan. 11. An FAA and industry working group is working on the new standard for AMT knowledge and skill requirements. The ACS is fundamentally an enhanced version of the practical test standards (PTS), with the addition of knowledge and risk management elements for each subject area. The result is a comprehensive document that outlines what an applicant needs to know, consider, and do in order to pass both the knowledge and practical tests for a mechanic certificate. See past member alerts on the ACS for more information about the document and its evolution. FAA and industry have teamed together to create the Airman Certification Standards (ACS). These documents will soon be replacing the Practical Test Standards (PTS) for select certificates and ratings.
This webinar will provide some historical perspective about the ACS and describe how it is used during a practical test specifically with regard to newly-released pilot ACS. Standards for mechanic testing are currently in development, participation in these webinars will therefore give technician educators an idea of what's to come. The next webinar is scheduled for Tues, Nov 15, 2016 1:00 PM - 2:00 PM CDT. Registration is available here. As part of the airman certification standards (ACS) development, the FAA's newly-created Aviation Exam Board (AEB) will be reviewing each question in the knowledge test bank. Its first round of edits will address the "low handing fruit"; that is, questions that should be removed from the bank entirely.
Through the ACS working group, the FAA is requesting feedback on the current general knowledge sample exam. Comments will be considered as the AEB begins their work to review and update the the knowledge test bank. ATEC will compile all feedback received from the membership for consideration by the AEB. Member comment is due to atec@atec-amt.org by Oct. 6. An FAA and industry working group continues development of the aviation maintenance technician airman certification standard, which will set the framework moving forward for the written, oral and practical A&P mechanic test. The initial draft combining general, airframe and powerplant is available for download here. Member comment is due to atec@atec-amt.org by Oct. 6.
The ACS is fundamentally an enhanced version of the practical test standards (PTS), with the addition of knowledge and risk management elements to each subject area. The result is a comprehensive document that outlines what an applicant needs to know, consider, and do in order to pass both the knowledge and practical tests for a mechanic certificate. The timing of ACS development and part 147 rulemaking activities gives our community a unique opportunity to ensure teaching requirements are in line with mechanic testing standards. ATEC will continue to request that AMTS have the ability to teach to that standard free of prescriptive requirements and defined subject areas. The ACS would naturally be the basis and framework for every AMTS teaching curriculum, which is why it’s so important that the AMTS community participate in its development. An FAA/industry working group is creating an airman certification standard (ACS) that will replace current mechanic testing standards (see previous stories here). Members that are helping to develop mechanic test standards include:
The first draft ACS, dictating general knowledge and skill testing standards is available for industry comment. The draft ACS was created over the course of several weeks and is a compilation of the general practical testing standard (FAA-S-8081-26A), the general knowledge test guide (8082-3A), the FAA “oral and practical test generator”, and the 2009 part 147 aviation rulemaking advisory committee recommendation (see page 69). The steps taken to create the draft ACS is memorialized in the May and June working group meeting minutes; those seeking additional information on the inclusion or exclusion of particular subject areas should reference those minutes or contact a member of the working group. Send edits, comments and recommendations to atec@atec-amt.org by July 8. By: Jackie Spanitz, Curriculum Director, Aviation Supplies & Academics
An FAA and industry working group are currently developing new airman certification standards (ACS) which will replace current practical test standards (PTS). The ACS will dictate the knowledge and skill needed to obtain an FAA mechanic certificate, including those tested through both the oral and practical (O&P) and written exams. The purpose of the new ACS is to ensure applicants, educators and evaluators understand what the FAA expects an applicant to know, consider, and do in each phase of the certification process. The first ACS was initiated in 2011 as an effort to fix the pilot knowledge tests. With many questions that seemed outdated, irrelevant and more “tricky” than “meaningful,” test preparation became an exercise in memorizing correct answers solely for the purpose of passing the test. The first ACS for Private Pilot Airplane and Instrument Rating Airplane applicants is effective June 2016. Given the similar challenges presented in mechanic certifications, the pilot working group was expanded to include maintenance. Once the mechanic ACS is established, an FAA/industry review board will evaluate all general, airframe and powerplant knowledge exam questions against the ACS. If a question no longer “fits” (because it is not relevant, meaningful, or current to today’s technologies, regulations and practices), it will be rewritten or tossed. New questions will be written consistent with the ACS. In this way, the ACS will serve as guidance for the test writers, ensuring applicants are tested on subjects that really matter to safe maintenance operations. ATEC has a big role in developing the new ACS, get involved to ensure your curriculum and training guidance remain aligned with the FAA testing standards. You can also visit and subscribe to the FAA airman testing web page to stay informed of FAA activities. Jackie Spanitz is curriculum director for Aviation Supplies & Academics (ASA, Inc.). She has participated on all three of the committees that worked on the ACS development over the last five years. Having spent over 20 years working with FAA knowledge exams and documents, she is grateful to her industry and FAA colleagues who have worked so diligently to improve the training and testing environment. Questions? Contact her at Jackie@asa2fly.com ATEC's executive director and several AMTS representatives are part of a recently-expanded FAA/industry working group that will create procedures for developing and maintaining FAA mechanic test questions.
The working group was originally created in 2011 to revise pilot testing standards, which suffer from the same woes as its maintenance counterpart. The group developed an Airman Certification Standard (ACS) that serves as a guide for FAA test writers. The new ACS will roll out for instrument and private pilot certification this summer. The working group was expanded in response to ATEC's request that the mechanic test bank be released for review and comment. ATEC is hopeful that the "compromise" position, development of a working group to address the root cause, will provide a framework to ensure mechanic certificate applicants aren't forced to memorize incorrect answers and study outdated material. For more information on the working group's activities, visit the Airman Testing web page. On June 29, ATEC appealed the denial of its Jan. 30, 2015 Freedom of Information Act (FOIA) request to make the A&P exam question and answer test bank available for public inspection. After receiving numerous reports of vague, inaccurate or unanswerable exam questions, the board determined that access to the test bank was essential to ensuring questions and answers are – first and foremost – correct, accurate and clearly written.
Although we are hopeful that we will prevail in our appeal, there may be an alternative—and perhaps more fruitful—avenue. While drafting the appeal we discovered that other segments of the aviation community had similar problems when their certification exams were removed from public scrutiny. In 2011, the Airman Testing Standards and Training Aviation Rulemaking Committee (ARC) was created to address concerns that the FAA’s testing standards and materials for pilots were not keeping pace with training methods and technology. The committee recommended that a group of industry professionals should be formed to “bolster” the development of the pilot exam. Indeed, ARC’s 2012 report concluded that “returning the question bank to the public domain—where it previously resided—is the most effective way by which the aviation industry and FAA can work cooperatively to review, revise, and better focus what knowledge applicants must demonstrate during [the exams].” [1] We contacted the authors of the report and were informed that there will be a part 147 ARC in the near future. Currently we are scheduling meetings to discuss how ATEC and its members can be involved in the process. We hope that by participating in the committee we can demonstrate that public oversight and coordination with part 147 schools is essential to ensure the integrity of the A&P exam. [1] Jens C. Henning ET AL., A Report from the Airman Testing Standards and Training Rulemaking Committee (ARC) to the Federal Aviation Administration (2012). On Jan. 30, ATEC submitted a Freedom of Information Act (FOIA) Request to the FAA seeking the release of every question and answer utilized for the aviation maintenance technician general, airframe and powerplant knowledge test (A&P test).
ATEC has recently received reports of vague, inaccurate or unanswerable A&P test questions. Only a few hundred sample questions are available, a small fraction of the total number in the “test bank.” Once the questions are made available, the council will ensure industry has the opportunity to review and comment on their accuracy and clarity. If you have questions or comments or have encountered similar issues with the A&P test, please contact atec@atec-amt.org. |
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