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In response to the pandemic and education's immediate need to deploy online learning in the midst of school closures, on March 12, 2020, the FAA published a memo directing its inspector workforce to provide regulatory relief for part 147 schools electing to provide A&P program content to students online (see related story).
Since the deviation memo and a subsequent revision (see M330-8000.1-G-2003-0718, dated April 1, 2020) were published, the number of certificated aviation maintenance training schools that received permanent and/or temporary authorization to provide provide content online has grown to 61 percent. (Before COVID, less than 5 percent of the 184 certificated schools had permanent distance learning authorization from the FAA.) FAA officials have stated that the agency does not intend to terminate the deviation memo anytime soon, and that barring any unforeseeable circumstances, it will remain in force through the 2021-2022 academic year. As a reminder, the memo alone does not provide schools the authority to provide FAA-approved curriculum online, but instead directs the FAA inspector workforce to approve distance learning programs using less stringent guidelines than what is currently directed in the 8900.1 guidance. While the deviation memo was welcome news for schools last spring, the part 147 interim direct rule (expected to publish in November 2021) will provide further relief. If promulgated as directed, distance learning programs will no longer require FAA approval. That is, schools will have the freedom to deliver content in whatever manner deemed most appropriate, and in line with their accredited programs. The FAA will check the quality of the education through assessment of the school's mechanic test passing rates, and by ensuring that the A&P curriculum aligns with airman certification standards. Get the latest information on the The New Part 147 landing page.
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The PARTT 147 Act, legislation that rewrites Title 14 CFR part 147, is part of the massive omnibus bill expected to become law by Christmas Day.
Introduced last December, the Act reached a major milestone when it endured Senate and House committee markup and was subsequently made part of the Aviation Safety Act earlier this month. That aviation bill was ultimately rolled into the omnibus Consolidated Appropriates Act of 2021 (see page 3030 of 5593), which includes--among a host of other provisions--funding extensions and coronavirus relief. Once passed into law, the bill will direct the FAA to remove the current part 147 and replace it with language drafted by the ATEC community. The new regulation will rely heavily on emerging airman certification standards, which will be the basis for part 147 program curriculum moving forward. The regulation also provides for "additional fixed locations" (e.g., to facilitate high school partnership programs), removes all reference to static curriculum and hour requirements, and, for federally-accredited institutions, no longer requires FAA approval of curriculum and grading systems. "This was a monumental win for the aviation industry, and will forever change the landscape of aviation technical education," said ATEC legislative committee chair and Southern Utah University Director of Global Aviation Maintenance Training Jared Britt. "After advocating for FAA regulatory relief for over a decade, a coalition of academia, labor, and industry came together to demand change. And look at what we accomplished." Indeed, earlier this month a group of 23 organizations sent a letter to House committee leadership, urging committee members to retain PARTT 147 Act language adopted in the Senate Commerce Committee's aviation certification reform bill. The coalition was backed by a steadfast and bipartisan group of congressional champions including Sen. James Inhofe (R-OK), Sen. Tammy Duckworth (D-IL), Rep. Don Young (R-AK), and Rep. Cheri Bustos (D-IL). "Our champions worked tirelessly on our behalf. Their staffers are first-class, and we could not thank them enough for the time and effort they dedicated to our industry over the last 18 months," said Britt. "The community is also indebted to ATEC's legislative and regulatory committee members, who worked tirelessly to draft and refine the legislative language, and to the scores that educated congressional leaders on the need for reform." ATEC extends a special thanks to its Change Masters (you know who you are!), the ones with the ideas that moved our community beyond its established practice, and forced their ideas into visions. A webinar is scheduled for Jan. 13 @ 1 PM CT to review and discuss the new rule. Under the law, the FAA is directed to issue the new part 147 on or about April 1 (no joke). A coalition of 23 organizations sent a letter to House committee leadership encouraging support for long-awaited part 147 reform. The PARTT 147 Act (S.3043/H.R.5427), a bipartisan, bicameral bill introduced last December, was included in the Senate Commerce Committee's reported draft of the Aircraft Safety and Certification Reform Act of 2020 (S.3969), but not in the House version of the bill (H.R.8408). The coalition urged committee leaders to retain the language in the final certification reform bill.
Industry has long pushed for a new part 147 through formal FAA rulemaking (see a full summary of our efforts here), and late last year doubled its efforts by calling on Congress for help. The recent Senate commerce committee markup was a big step in the legislative initiative, and provides a path forward for the community-drafted, performance-based part 147 to become law. "Leading up to the pandemic, part 147 programs were not able to meet industry’s workforce demand; outdated and burdensome regulatory requirements exacerbated an already short supply of aviation technicians," said the coalition in its letter to committee leaders. "Given the mass exodus of qualified personnel due to COVID-19, industry’s post-pandemic recovery is greatly dependent on its ability to efficiently and effectively replace the devastating loss of technical experience. Reform of part 147 is now more important than ever." For the Act to become law, House and Senate negotiators will need to agree to retain the PARTT 147 Act's language in the final version of the certification reform bill. It would then need the president's signature in early January, before the 117th Congress convenes. U.S. Sens. Jim Inhofe (R-Okla.), Jerry Moran (R-Kan.), Tammy Duckworth (D-Ill.), and Shelley Moore Capito (R-W.VA.), applauded the Commerce Committee’s inclusion of their bill to improve education and training curriculum at aviation maintenance technician schools as part of S. 3969, the Aircraft Safety and Certification Reform Act of 2020, which the committee passed today.
The Promoting Aviation Regulations for Technical Training (PARTT) 147 Act would establish performance-based regulations to ensure aviation maintenance education institutions have the flexibility to teach core curriculum reflective of the ongoing technical advances and innovation happening across the aviation and aerospace industry. Reps. Don Young (R-Ark.) and Cheri Bustos (D-Ill.) introduced the companion legislation in the House of Representatives. “I am glad to see our bipartisan legislation pass through committee today that would empower schools with the flexibility to teach core curriculum reflective of the technical advances and new innovative techniques happening across the aviation and aerospace industry,” Inhofe said. “Not only this, it would reduce restrictive government regulations and ensure schools are empowering students to become productive mechanics on the flight line or maintenance floor. Outdated regulations have prevented schools from implementing modern curriculum to teach students the skills necessary to maintain and repair modern, sophisticated aircraft. It’s time we make a change. I appreciate Chairman Wicker and Ranking Member Cantwell for working with us to advance the PARTT 147 Act today.” “Our academic institutions need flexibility and resources to teach the skills the aviation and aerospace industry require in order for students to feel confident in their trade, and meet the current demands of the industry,” said Moran. “Serving as the Senator for the ‘Air Capital of the World,’ I was pleased to support this legislation that will help our academic institutions prepare students for careers in the aviation and aerospace industry and look forward to supporting this legislation in the full Senate.” “I’m very proud to see the bipartisan PARTT 147 Act advance through the Senate Commerce Committee,” Duckworth said. “We’ve seen important innovation and advancements in the aviation industry over the past 50 years and, to keep pace, we need to make sure our workforce is prepared to meet today’s technical demands. This effort will help modernize aviation maintenance educational programs and improve their overall efficiency and effectiveness to further enhance Illinois’s classroom-to-workplace pipeline.” “The Commerce Committee’s passage of the Aviation Safety and Certification Reform Act not only would make much needed reforms to improve aviation safety, but includes legislation that is important for the emerging aerospace industry in West Virginia,” said Capito. “The inclusion of our bill updates outdated regulations and ensures aviation maintenance education institutions have the flexibility needed to teach a curriculum that reflects the ongoing technical advances that are occurring across the aviation and aerospace industry. I am confident that the inclusion of this bill will go a long way in improving the training programs at maintenance technician schools.” Stakeholder Support: A number of stakeholders wrote a letter of support for The PARTT 147 Act of 2019, which can be viewed here. A letter from Oklahoma stakeholders can be found here. Background:
The council will facilitate three online webinars next month, highlighting issues impacting the aviation technical workforce. Register now for these upcoming events:
**Updated Oct. 21, 2020***
The Safety Assurance System (SAS) is an FAA oversight tool for certification and surveillance. It is most well known by industry as a software tool to collect data through utilization of Data Collection Tools (DCTs). The purpose of the program is to facilitate a risk-based, data-supported approach to oversight and standardize evaluation protocols. Part 135, 142, and 145 certificate holders are currently subject to the SAS approach. Representatives of those sectors have argued that implementation missed the mark given questions are not weighted and therefore the system does not ensure resources are focused on the most vulnerable. Industry also contends that the prescriptive nature of the DCTs is contrary to the FAA’s movement towards performance-based rules, and that the majority of the questions are based in guidance and policy, not in regulations. While the FAA contends that "SAS is not a separate safety standard and does not impose additional requirements on certificate holders," those subject to the oversight system have raised concerns that while industry's use of the portal is "voluntary," the DCT's are not optional for the safety inspectors and there is an unspoken expectation that the certificate holders complete them, especially if it means assisting the inspector in an expeditious document review. For part 147 holders, the expansion could mean more man hours required for certification and/or FAA audits. (For example, a charter operator reported that it was asked to complete over 570 SAS questions in response to its request for an operations manual revision.) Given those realities, industry has asked the FAA to add industry representation to FAA internal SAS groups, or at the very least develop a list of stakeholders to provide feedback on how to improve the system. While ATEC engages with regulators on these issues, the community is encouraged to review the SAS elements applicable to part 147 certificate holders, and report back concerns or comments: SAS FS Data Collection Tools (DCTs) DCTs applicable to part 147 certificate holders:
In a letter to Senate Commerce Committee Ranking Member Maria Cantwell and House Aviation Subcommittee Chair Rick Larsen, a group of Washington state-based schools and organizations called on Congress to support the Promoting Aviation Regulations for Technical Training (PARTT) 147 Act (S.3043/H.R.5427).
The Act, which was introduced in December and since garnered a long, bipartisan list of co-sponsors in both the House and the Senate, would direct the FAA to remove and replace the current part 147 with community-drafted language. If passed into law, the new, performance-based regulation would replace prescriptive and duplicative operational requirements and curriculum hour and subject area mandates that have long-awaited agency action. "Seeing no regulatory relief in sight, the undersigned organizations acknowledge that the Act is intended to further escalate the issue after 12 years of pushing for a new rule to modernize aviation maintenance technician training," the coalition stated in its letter. "Promulgation of the Act’s performance-based regulation would give schools and employers the freedom to develop programs that better align with industry needs, and ensure individuals begin their careers equipped to hit the ground running." Nine representatives of WA-based organizations signed on to the letter, including four college presidents overseeing part 147 programs at their respective institutions:
The Act is awaiting consideration by committees with jurisdiction over aviation issues in both the House and the Senate. Members of the community are encouraged to reach out to their own elected leaders to voice support for the bill. An online legislative toolkit is available to guide those efforts. Title 14 Code of Federal Regulations (CFR) part 147 governs aviation maintenance technician schools and mandates what our technical programs teach aspiring aviators. The regulation was originally established in 1962 and has not been significantly revised since. For over a decade, the council has actively advocated for a new part 147, imploring the Federal Aviation Administration to promulgate a regulation that would release schools from unnecessary restrictions and allow the community to properly prepare future aviators for their aspiring careers. With no relief in sight, the community asked Congress for help. In a bipartisan effort, House and Senate leaders introduced The Promoting Aviation Regulations for Technical Training (PARTT) 147 Act (S.3043/H.R.5427), legislation that, if signed into law, would direct the FAA to reform the out-dated regulation and promulgate a community-drafted rule that would allow schools to innovate while removing unnecessary restraints with no impact on aviation safety. The inflexibility of the current rule is especially acute in the COVID-impacted environment. Under the current regulatory framework, schools must obtain FAA approval before providing aviation technical program content online. The restriction is yet another example of unnecessary regulatory interference that ultimately deprives students of their ability to complete their course of study. ATEC is therefore doubling down on its efforts to generate support for the Act, and asking that Congress consider including it in any must-pass legislation this Congress. The PARTT 147 Act would adopt a performance-based approach, whereby the FAA would defer to Department of Education oversight for all matters concerning quality of education, and give schools the freedom to create curriculum based on competencies and industry needs. Community leaders are encouraged to take the following steps to solicit congressional support for the PARTT 147 Act:
Congress Introduces Legislation to Modernize 50-Year-Old Aviation Maintenance Training Regulation12/12/2019 December 12, 2019
For Immediate Release Contact: Crystal Maguire, crystal.maguire@atec-amt.org, 703-548-2030 JENKS, Oklahoma – Today, members of the U.S. Senate and House of Representatives issued bipartisan, bicameral legislation that, if signed into law, would modernize long-outdated maintenance training regulations and better aid the education community in supporting America’s growing aviation industry. The Promoting Aviation Regulations for Technical Training (PARTT) 147 Act (S.3043/H.R.5427) would direct the Federal Aviation Administration (FAA) to replace current training requirements with a new, community-drafted regulation that would establish a performance-based oversight system. Under the new law, aviation maintenance technician schools certificated and governed by Title 14 Code of Federal Regulations part 147, would have the flexibility to teach content that is reflective of today’s high-tech environment. Senators James Inhofe (R-OK), Tammy Duckworth (D-IL), Jerry Moran (R-KS), Shelly Moore Capito (R-WV) and Representatives Don Young (R-AK) and Cheri Bustos (D-IL) are original co-sponsors of the PARTT 147 Act. “Innovation in the aviation and aviation maintenance industries has led to safer and more efficient aircraft. However, outdated regulations have prevented schools from implementing modern curriculum to teach students the skills necessary to maintain and repair modern, sophisticated aircraft,” Inhofe said. “I am proud to introduce this legislation today which would empower schools with the flexibility to teach core curriculum reflective of the technical advances happening across the aviation and aerospace industry, would reduce restrictive government regulations, and would ensure schools are graduating successful students into productive mechanics on the flight line or maintenance floor.” “When it comes to transportation, Alaska’s unique geography can present many challenges. Aviation is one of the most important means of traveling our state, and the demand for air travel requires a strong workforce of both aviators and the mechanics who support them,” said Young. “Current FAA regulations mandate a particular curriculum for maintenance technicians, but this curriculum has not been meaningfully updated in more than five decades. The PARTT 147 Act is a fix that is long overdue.” “The new regulation would be a game changer for aviation programs,” said Pittsburgh Institute of Aeronautics Director of Campus Operations and ATEC President Gary Hoyle. “Industry has been asking for an updated regulation for 15 years. It is past time for our community to be given the opportunity and flexibility to create programs that better meet demand for highly-skilled technical personnel. We applaud the leadership and willingness of our congressional representatives to further escalate the issue and provide long-awaited relief from prescriptive requirements.” An overwhelming number of aviation stakeholders signed on to a letter in support of the PARTT 147 Act, including-- Accrediting Commission of Career Schools and Colleges Aeronautical Repair Station Association Aerospace Industries Association Aerospace Maintenance Council Aircraft Electronics Association Aircraft Mechanics Fraternal Association Aircraft Owners and Pilots Association Airlines for America Association for Women in Aviation Maintenance Aviation Suppliers Association Aviation Technician Education Council Experimental Aircraft Association General Aviation Manufacturers Association International Air Transport Association International Brotherhood of Teamsters Modification and Replacement Parts Association National Air Carrier Association National Air Transportation Association National Business Aviation Association Professional Aviation Maintenance Association Regional Airline Association The Aviation Mechanics Coalition The stakeholder support letter can be found here. The full text of the bill can be found here. An ATEC one-pager on the issue can be found here. For more information about industry’s work to modernize part 147, including resources and a timeline of events, visit www.atec-amt.org/part-147. ### About ATEC: ATEC is a partnership of aviation maintenance training schools and employers. The council is dedicated to promoting and supporting technician education through its communications, advocacy programs and networking events. To learn more, visit www.atec-amt.org. Last week, ATEC announced that congressional leaders were gearing up to introduce legislation that would direct the FAA to promulgate very specific, community-drafted language in place of the current 14 CFR part 147. The initiative stems from proposed language ATEC offered in its comments to the recent FAA part 147 supplemental notice of proposed rulemaking (SNPRM). If signed into law, provisions would require FAA deference in all matters concerning quality of education and set forth a performance-based infrastructure whereby schools would utilize emerging airman certification standards as the basis for their curriculum. Click on the image below and listen to the recorded version of the live briefing, which took place Nov. 19, 2019. (Things may have changed by the time you hear it!). You may also download the slide deck here. ATEC members can access the full suite of pre-recorded webinars at www.atec-amt.org/webinars.  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. The trade association highly recommends that the community provide feedback on the recent supplemental proposal. Comments are due Monday, June 17.
To aid those efforts, the council has created two templates--one for AMTS and one for industry--to facilitate meaningful feedback. It is important to note that submission of the "form letters" provided below do not count as a "vote" for or against the proposal. ATEC's intention is for the community to provide real-world examples that support the positions set forth in the council's comment submission. Instructions for submitting comment:
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. US Senators Orrin Hatch (R-UT), Maria Cantwell (D-WA), James Inhofe (R-OK), and Richard Blumenthal (D-CT) introduced a bill to improve training programs at aviation maintenance technician schools. If enacted, the statute would require Federal Aviation Administration (FAA) promulgation of a new part 147 within six months. The regulation that governs aviation maintenance technician schools has not been significantly revised since it was re-codified into the Code of Federal Regulations in 1962.
Industry has fought long and hard for a revision to part 147, which dictates static curriculum requirements for schools teaching future aviation mechanics. Over the past decade, representatives have provided specific recommendations through a 2007 Aviation Rulemaking Advisory Committee, proposed regulatory language in its comments to the 2015 notice of proposed rulemaking, responded to additional requests for information through submission of supplemental comments and facilitation of surveys, and participated in working groups that will improve mechanic testing standards and correlated training programs. "While the education community will continue to lend support, and appreciates the time and effort required for well thought out and monitored rulemaking, it refuses to sit by and wait for regulatory relief while industry and our students continue to pay for outdated training regulations," said ATEC Legislative Chairman and Southern Utah University Director of Maintenance Jared Britt. This is not the first time congress has pushed for a new rule. In the last three years, congressional representatives have sent four letters to the agency requesting a status update. "It was time we did something more than just inquire, and we are grateful that our elected leaders are taking the next step," said Britt. An industry coalition—spearheaded by ATEC—sent a letter in support of the bill, asking Congress to support the future aviation workforce, in support of an industry constantly driving for more innovative, safer and more efficient aircraft. Signatories of the letter included: Aeronautical Repair Station Association Aerospace Industries Association Aerospace Maintenance Council Aircraft Electronics Association Aircraft Mechanics Fraternal Association Airlines for America Association for Women in Aviation Maintenance Aviation Maintenance Technician Association Aviation Suppliers Association Aviation Technician Education Council Cargo Airline Association Helicopter Association International International Air Transport Association Modification and Replacement Parts Association National Air Carrier Association National Air Transportation Association National Business Aviation Association, Inc. Professional Aviation Maintenance Association Regional Airline Association Women in Aviation International The statute would also require that curriculum be revised and updated in coordination with emerging aviation maintenance technician airman certification standards, something an industry working group helping to develop the new standard has already recommended. While the text has not been officially published as of the date of this post, it will soon be available at www.congress.gov/bill/115th-congress/senate-bill/2792?r=6. Senate media releases: Inhofe: www.inhofe.senate.gov/newsroom/press-releases/inhofe-hatch-cantwell-blumenthal-introduce-bill-to-modernize-aviation-maintenance Hatch: www.hatch.senate.gov/public/index.cfm/2018/5/hatch-and-bipartisan-senators-introduce-bill-to-modernize-aviation-maintenance Cantwell: www.cantwell.senate.gov/news/press-releases/cantwell-colleagues-introduce-bill-to-modernize-aviation-maintenance Southern Utah University (SUU) petitioned the FAA for an exemption from part 147 seat time and general curriculum requirements. The University requested that it be allowed to utilize emerging airman certification standards as the basis for its new A&P program curriculum.
In its comments, ATEC voiced its support for "any innovative solution that will enable AMTS to provide quality programs, despite static curriculum requirements that do not reflect the needs of today’s employers." Council representatives have long fought for a new part 147. If successful, the petition would provide an alternative path for schools to cater their A&P programs to local employer needs. A summary of the council's part 147 advocacy efforts are available at http://www.atec-amt.org/part-147.html. Public comments close April 18. The petition is available at www.regulations.gov/docket?D=FAA-2018-0215. Update: The following post was published in September 2017. As of December 2017, the FAA has not yet issued the expected supplemental notice of proposed rulemaking for part 147. Agency officials have stated that the rulemaking is still in progress and is expected to publish "soon."
The aviation maintenance technician school docket was recently revised to include a second NPRM in its regulatory plan timetable. According to the revision, a Supplemental Notice of Proposed Rulemaking (SNPRM) will be published in October 2017. An SNPRM is generally issued when a proposed rule has been substantially changed from the original notice of proposed rulemaking. The supplemental notice advises the public of the revised proposal and provides an opportunity for additional comment. Given developments with Airman Certification Standards since the original NPRM was issued, and strong comments by ATEC and other industry groups calling for a less prescriptive rule with opportunity for competency-based training systems, the council is optimistic that the revised proposal will provide a better framework for aviation maintenance school programs. While the additional step will likely delay promulgation, ATEC is confident that another round of review and comment will help ensure the next iteration of part 147 will last the test of time. Stay tuned. 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. Utah Senator Orrin Hatch made formal inquiry into the status of the anticipated revised proposal for 14 CFR part 147, the regulation governing curriculum requirements for aviation maintenance technician schools.
In addition to the update, Sen. Hatch highlighted the need for a rule that provides more flexibility: "As you may know, Utah schools are home to many aviation education programs, including those for aviation maintenance technicians. I have repeatedly heard from constituents who wish to have updated, less burdensome regulations for these programs. I share in their concerns that the rule is in major need of an update to keep up with the expanding global aviation sector and modernized aircraft." The FAA has stated than an SNPRM will be issued in October 2017. Council activities are ramping up in anticipation of new airman certification standards and a revised part 147. The webinar provides an overview of potential changes, tips on how to prepare, and access to practical resources so schools and companies alike can start planning now. Opportunities are available for all stakeholders to help ensure aviation maintenance technician school curriculum adequately prepares the future workforce.
All members receive free access to the recorded version, available in the ATEC Webinar Library. ATEC is initiating a grassroots campaign to garner legislative support for expeditious issuance of the new part 147. To support those efforts, ATEC contributed an opinion article to a leading political publication, The Hill. The piece highlights the ever-growing need for a modernized regulation governing aviation maintenance technician training. It will be used to educate lawmakers on the issue during the council's annual Fly-In, held each year in Washington DC.
Read and share the article, found here: http://thehill.com/blogs/pundits-blog/transportation/345631-aviation-struggles-with-50-year-old-maintenance-training Lots of behind-the-scenes activity is taking place in preparation for the new part 147. The expectation is that a new rule will be issued this summer, so it’s a good time to sit back, take a breath, and assess where we’re at, and opportunities coming down the pike.
First, a quick recap: Title 14 Code of Federal Regulations (CFR) part 147 governs aviation maintenance technician schools that hold a Federal Aviation Administration (FAA) certificate. The regulation was originally established under the Civil Aviation Administration and re-codified into 14 CFR in 1962. Since that time, neither the regulation, nor the subject areas it dictates be taught, have significantly changed. During the same time, the design regulations mandating the standards to which a civil aviation article must be certificated and maintained have changed innumerable times. These changes have enhanced safety significantly; they also mandate more sophistication and knowledge in maintenance personnel. Everyone agrees the rule needs revising. A 2003 Government Accountability Report (GAO) report called for updates to curriculum requirements, recognizing that certificated programs do "not fully prepare A&P mechanics to work on commonly flown, technologically advanced commercial aircraft,” and that “today’s modern aircraft require A&P mechanics to have a different set of skills than those being taught at aviation maintenance technician schools.” An Aviation Rulemaking Advisory Committee, made up of industry and FAA representatives, issued a December 2008 report with specific recommendations to update static minimum curriculum requirements dictated in part 147. Since then, ATEC has been at the forefront of the demand for change. In November 2015, the FAA issued a part 147 notice of proposed rulemaking. ATEC submitted extensive comments, calling for a less-prescriptive rule that would allow for competency-based programs and the freedom to cater training to industry needs. ATEC’s position was supported by 14 aviation organizations, discouraging the NPRM’s continued reliance on class time at the expense of technical capability. To continue the momentum, ATEC representatives held face-to-face meetings, submitted supplemental comments and garnered legislative support for a rule that would provide better trained personnel to meet industry workforce needs. During roughly the same period of time, an FAA-industry working group undertook a massive effort to improve airframe & powerplant (A&P) mechanic certification testing. The Aviation Maintenance Technician (AMT) Airman Certification Standards (ACS) will 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. Promulgation of the new part 147 and AMT ACS development couldn’t be more perfectly timed. The new rule will utilize operations specifications in lieu of static curriculum requirements; industry’s hope is that those operations specifications will simply reference the ACS, ensuring that training and testing are directly correlated. What’s more, the joint FAA-industry committee will periodically review and update ACS standards to ensure it is in line with mechanic knowledge and skill requirements as technology evolves. And, under a new rule allowing for competency-based programs, AMTS can focus on ensuring a student can demonstrate required knowledge, skills and attitudes (as defined in the ACS!), instead of required training hours. ATEC Treasurer and Embry-Riddle Aeronautical University Associate Professor and Department Chairman Chuck Horning has volunteered hundreds of hours to help usher through the new generation of regulations and standards, “We have an incredible opportunity right now that probably won’t happen again. We started this initiative hoping for a rule change and never dreamed we would have the opportunity to improve the testing process. Now we have the chance to do both and have all the pieces of the puzzle fit like they should.” ATEC will continue to engage with the agency and congressional leaders to support timely promulgation and smooth implementation. The council will also ensure its member schools have the tools and resources required for a successful transition; webinars, curriculum guides, tools and resources are in development. Take advantage of all ATEC has to offer, and support the council's workforce development efforts, by ensuring your membership is current. As part of its efforts to support the impending part 147 rulemaking, the FAA requested that ATEC facilitate a short survey of all current part 147 aviation maintenance technician schools. The survey addressed three areas: 1) the design of competency-based programs; 2) the implementation of competency-based programs; and 3) the extension of course offerings through dual enrollment programs.
Sixty two of the 175 certificated schools responded. Of those, 61% stated they would implement a competency-based program if allowed under the new regulation (22% were unsure and 16% said they would not utilize competency-based curriculum). When asked whether their school would offer courses away from the fixed location (e.g., as part of a high school dual-enrollment program), 66% responded in the affirmative, including 8% that already have some form of dual-enrollment program. Responses provided strong indication that these opportunities would increase student enrollment. The data will support an economic analysis that is expected to accompany the final rule. 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. |
ATEC NewsStay tuned for updates on everything ATEC members need to know as well as ways that you can help the council and the AMTS community. Categories
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