As part of the Council's annual fly-in, aviation maintenance technician school (AMTS) representatives met with FAA officials to discuss several regulatory matters of importance to ATEC's membership. Agenda topics included the agency's reluctance to support AMTS-high school partnerships, the shortage designated mechanic examiners and the need for a part 147 regulation that would allow AMTS to develop competency-based programs.
While the agency could not discuss the pending part 147 regulation given ex parte limitations (a summary of the meeting will be provided to the docket for public inspection), officials listened as attendees spoke on the benefits of a competency-base rule that would provide AMTS the opportunity to meet agency testing standards free from prescriptive requirements (seat time, subject requirements, etc.).
Participants pointed out that competency-based systems are widely-supported by the education community including the Department of Education, and are proven to provide efficient and effective educational programs. Removing prescriptive requirements from the proposed rule would also be in line with the agency’s efforts to implement risk-based oversight. That is, given the low-risk associated with AMTS, FAA resources currently utilized to enforce regulatory requirements such as grading systems, seat time, availability of missed material, etc., could be better utilized in higher risk areas. Further, AMTS operations and the manner in which it educates its students are better overseen by Department of Education and accreditors.
Industry representatives also addressed the agency's concern in the local inspector’s ability to enforce a competency-based rule and measure the effectiveness of its program. AMTS representatives pointed out that the current rule does not provide the framework to measure program effectiveness (i.e., inspector checklists are focused on attendance records and grading policies), and that the AMTS “effectiveness” would ultimately be measured through the mechanic test, which the FAA controls. Ultimately, the agency will only issue a mechanic certificate to those applicants that possess the requisite skill and knowledge, as provided for in the written, oral and practical tests.
Industry representatives also discussed the development of new airman certification standards (ACS) and how those standards should be utilized in the final rule. Once the ACS is developed, the standards could be incorporated into an AMTS operations specifications, to include specific objectives and teaching levels as needed. That way the AMTS would be “required” (through op specs) to teach those items provided for in the mechanic test.
In closing, industry asked the agency to duly consider the benefits of allowing AMTS to implement modern educational systems that other industries have long utilized. They asked agency representatives to permit programs that transition away from seat time in favor of a structure that creates flexibility, and allows students to progress as they demonstrate mastery of subject matter, regardless of time, place, or pace of learning. This type of rule would encourage free-flow of A&P mechanic applicants to an industry that desperately needs a competent and qualified workforce to support continued operations.
ATEC will continue to engage on this topic in anticipation of the new part 147, expected to be issued in the summer of 2017.
In response to an FAA inquiry regarding ATEC's request for a competency-based part 147 regulation, ATEC submitted supplemental comments to the part 147 notice of proposed rulemaking.
Redefining the use of time is the single most significant policy enabler for competency-based learning models; ATEC therefore reiterated its request that the agency remove all prescriptive requirements from part 147, which would allow AMTS to incorporate competency-based learning models into their programs. The supplemental comments also gave specific examples on how AMTS programs could change under a competency-based regulation, and relieve FAA of burdensome and unnecessary oversight responsibilities.
The comments supplement ATEC’s previous comments to the NPRM, and an aviation industry coalition letter and STEM coalition letter in support of those comments.
On Feb. 22, the STEM Education Coalition, an alliance of more than 500 business, education and professional organizations, submitted comments to the FAA part 147 notice of proposed rulemaking (NPRM). In its letter, the group expressed its support for a maintenance technician competency-based learning system that allows industry to freely meet already-mandated knowledge, skill and experience standards.
The coalition’s comments echoed ATEC’s concerns that the NPRM goes beyond the FAA’s basic mandate to oversee and regulate safety in the aviation industry and that educational oversight is a responsibility best left to other executive branch agencies, stating in part: “Our Coalition supports education policies that are flexible and responsive to the needs of the global economy. As proposed in the NPRM, FAA mandates on teaching times, passing norms, maximum levels of instruction, student/teacher ratios, and static curriculum topics are not hallmarks of a modern, competency-based structure that industry desperately needs. These requirements lead to waste and increased costs for industry and students pursuing a STEM education.”
As a member of the coalition’s leadership council, ATEC furthers the group’s mission to educate government about the impact STEM education has on the global economy and to ensure student success in technical fields. Learn more about the coalition’s good work at the April 9-12 annual conference in Atlanta, or at http://www.stemedcoalition.org/.
On Feb. 1, ATEC led a broad effort to get the new part 147 right. The council submitted comments to the FAA’s notice of proposed rulemaking (NPRM) and organized an industry-wide effort to demand a competency-based rule.
ATEC’s comments, developed by a working group of AMTS representatives, provided a roadmap that would allow institutions to tailor their programs while adhering to agency standards. “Industry has suffered the repercussions of an outdated rule for far too long,” the comments said. “[Aviation maintenance technician school] students have been forced to spend wasted effort and time learning antiquated skills, and industry has borne the cost. We desperately need a competency-based rule that gives educators flexibility to teach the future workforce the skills needed to support the ever-changing, technology-driven, dynamic aviation industry.” The comments also provided specific regulatory language to aid swift issuance of a final rule.
To further highlight the need for a competency-based rule, ATEC sought assistance from its industry allies. In a separate submission, 14 organizations decried the NPRM’s continued reliance on class time at the expense of technical capability.
“Put simply, the proposal would impose 20th century educational practices on a 21st century industry,” the group, which included Airlines for America, the Aeronautical Repair Station Association and a broad swath of aviation, maintenance and educational interests, said. “It maintains its predecessor’s antiquated concern with the time a student spends in a classroom seat rather than focusing on the skills he or she actually gains. A competency-based standard, free of defined schedules and specific hour requirements, will allow industry to transition away from seat time in favor of a structure that creates flexibility and allows students to progress as they demonstrate mastery of subject matter, regardless of time, place, or pace of learning.”
While part 147 is the regulatory foundation for ATEC’s member institutions, the council- led effort serves a larger purpose. As its allies have recognized, getting the AMTS rule right means effective schools, competent students and a flourishing aviation community.
Stay tuned as ATEC continues to push for an efficient rulemaking process that culminates in the best possible rule.
To view the council’s comments, click here.
To view the combined industry comments, click here.
ATEC officially enlisted Congress in the council’s effort to update 14 CFR part 147. After weeks of development, Representatives Tom Rice (S.C.) and Jim Bridenstine (Okla.) sent a letter asking the FAA to make the rulemaking its highest priority.
To ensure a final rule is issued efficiently, the letter emphasized that the “outdated part 147 mandates hinder the aviation maintenance industry's ability to compete and grow” and encouraged the agency to “continue on the course identified in the Notice of Proposed Rulemaking.”
The effort to produce a final rule updating 147 is a top priority for ATEC. Stay tuned as the council continues to use every avenue to improve AMTS’s regulatory foundation.
February 2, 2016 update: Administrator Huerta responds to the congressional letter, stating in part "The part 147 rulemaking is among the highest priorities for the FAA. We are committed to delivering regulation that encompasses new technology and remains flexible to grow and adapt with the industry... The FAA will proceed with this rulemaking as timely and efficiently as possible while adhering to the requirements of the Administrative Procedures Act."
The part 147 rulemaking working group continues to develop ATEC’s comments to the aviation maintenance technician school notice of proposed rulemaking (NPRM) (see previous stories here, here, here and here). The working group will solicit member feedback on the proposed rule, giving the council time to finalize and gather industry group support before submission. Comments to the NPRM are due Feb. 1, 2016.
The part 147 rulemaking working group continues to develop ATEC’s comments to the proposed part 147 rule (see previous stories here, here and here). Thank you to the following industry volunteers who are giving their time to the cause--
On Nov. 19, the Federal Register published the FAA's intention to extend the comment period for its proposed update to 14 CFR part 147. The move came in response to a request from 14 aviation and education groups, led by ATEC, submitted in late October.
"[The final rule will impact] not only the hundreds of institutions that educate our workforce, but also the thousands of businesses that rely on AMTS graduates to keep aircraft in flight," the coalition explained in its extension request. "With the additional time requested, the aviation industry and its partners in technical education will help the agency develop a rule that supports schools, aids students at the beginning of a rewarding career and serves an important and growing industry."
Comments are now due by Feb. 1, 2016. While the agency opted against providing the 90 additional days requested by the aviation community and its technical education allies, AMTS must fully utilize the time available to ensure robust guidance is provided to regulators.
Now that the deadline is set, the council and its allies can focus on substantive comments. Members are encouraged to review the proposal (see ATEC's side-by-side comparison) and submit feedback to email@example.com.
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.