Earlier this month an ATEC contingent descended upon Washington, D.C. for its annual Fly-in. This pilgrimage happens each fall to push legislative and regulatory action, meet with key leaders, and conduct critical business for the organization.
The event kicked off with a roundtable discussion with FAA officials. Flight Standards Service Deputy Executive Director Larry Fields and Deputy Director Office of Safety Standards Van Kerns were joined by 12 of their colleagues to discuss a laundry list of regulatory issues impacting certificated part 147 schools.
Coming off the recent publication of the part 147 supplemental notice of proposed rulemaking, attendees discussed the impact proposed mandates would have on schools, and the role of accrediting bodies vs. the FAA in overseeing educational quality elements in their technical programs. ATEC strongly suggested—as it did in its comments to the SNPRM—that the FAA defer to Department of Education accreditation requirements on all matters concerning educational oversight, and took the opportunity to educate officials on the role of accreditors. (See presentation by Aviation Institute of Maintenance Vice President Joel English, The Triad in Higher Education.)
The council then discussed a formal letter it sent the week prior, asking the FAA to provide for part 147 “additional fixed locations,” and better facilitate maintenance program expansion into high schools (see related story, below). FAA representatives also gave updates on airman testing system improvements and the anticipated expansion of the Organization Designee Authorization program, an effort that would greatly expand access to testing for mechanic certificate applicants (see related story).
A lunch briefing by Aeronautical Repair Station Association Executive Vice President Christian Klein gave attendees an update on the grant programs authorized under the recent FAA reauthorization bill (see related story). Klein encouraged attendees to educate congressional leaders on the need to include funding in 2020 appropriations legislation so that the Department of Transportation can implement the program as directed (See related story, below).
Klein was joined by Policy Advisory for Senator James Inhofe (OK) Dan Hillenbrand who briefed attendees on a new legislative effort to push part 147 rulemaking. The Senator has championed several legislative initiatives (including a provision in the FAA reauthorization bill mandating promulgation of part 147 within six months, see related story). The latest legislative effort would direct the agency to issue an ATEC-drafted part 147 within 90 days.
The legislative effort leverages regulatory language provide in the council’s comments to the SNPRM (see related story), and mandate that the agency promulgate the language as written by the ATEC community. The plan was initiated after the agency suggested a final rule is still two years away, and publication of a less-than-optimal supplemental proposal (see related story).
Attendees were presented with a discussion draft of the legislation in order to solicit review and comment from the community and legislative leaders (see issue page with more details on the proposal). Hillenbrand asked that the community identify potential Senate co-sponsors, as well as House leaders willing to introduce companion legislation on the House side. A final bill is expected to be introduced soon.
The day concluded with briefings on federal initiatives impacting career technical education from representatives of the STEM Education Coalition and the White House Office of Science and Technology Policy. STEM’s James Brown and the White House’s Cindy Hasselbring informed attendees on how the council might better align their regulatory and legislative priorities with the Administration, and what resources are available to help the industry communicate their issues and proposed mandates.
A workshop to kick off the first research phase of Choose Aerospace—an organization created to advance awareness in aviation maintenance—rounded out the day. Level 7 Market Research Senior Managing Partner Kathleen Costello led attendees in an open discussion to supplement the firm’s findings at a recent student focus group—held at the University of the District of Columbia Community College. The research project is initially focused on marketing best practices for attracting new talent into the workforce pipeline. Information gathered from students at UDCCC and attendees at the ATEC Fly-in will publish in an initial report later this year.
After a full day of briefings on the issues, attendees were well prepared for meetings with congressional leaders the following day. Aviation maintenance education representatives held 44 meetings pushing ATEC’s top legislative issues, including garnering support for federal grant funding and legislation to fast-track an ATEC-drafted part 147. Efforts were successful, with congressional leaders overwhelmingly in support of all ATEC’s priorities.
After two days of briefings, meetings, and fellowship (thanks to AMFA, AVOTEK, AIM, Piedmont for keeping us fed and watered!), the ATEC board of directors held is semi-annual, in-person meeting to discuss council business. Directors voted in favor of a funding plan that will support the next phase of ATEC development. A 2020 dues increase will support the creation of a new charitable organization that will administer scholarships previously available to aviation maintenance programs and students through the Northrop Rice Foundation, and facilitate the Choose Aerospace coalition. Members will receive additional information about these exciting next steps in the coming weeks.
Thanks to all the speakers, sponsors, and attendees that made this year’s Fly-in a success. Through events like the Fly-in, ATEC ensures your voice is heard. If you weren’t able to participate in Washington there are more ways to get involved. Invite a member of congress to your school and show them what you do in your community. Volunteer to serve on an ATEC committee. Attend our annual conference next April in Fort Worth. Join us in building the future.
Download event materials, speaker presentations, and photos at atec-amt.org/fly-in-2019.
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.
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:
To brief the community on the particulars on the recent Federal Aviation Administration Title 14 Code of Federal Regulations part 147 Supplemental Notice of Proposed Rulemaking (SNPRM), and to assist stakeholders with their own comments (due June 17, 2019), the council held an online webinar on May 30. The recorded version is available for free to all members of the community.
On May 6, a coalition of 16 aviation industry associations jointly submitted comments to the FAA’s Draft Advisory Circular (AC) 65-30B, “Overview of the Aviation Maintenance Profession.” Led by the Aeronautical Repair Station Association (ARSA), the group continued work begun in 2014 when the agency last released a draft version of the AC – which hasn’t been officially updated since 2001. (See related story.)
“As representatives of persons involved in the design, production, operations and maintenance of civil aviation products and articles, each organization supporting these comments depends on a vibrant pool of talented aviation maintenance professionals to ensure safety worldwide,” the group explained in its submission. Comments focused on illustration of the breadth of opportunities available in aviation maintenance, including noncertificated professionals, certificated repairmen, certificated mechanics, mechanics holding inspection authorization and transitioning military personnel.
“There is no single point of entry or career trajectory for aviation maintenance professionals,” the draft industry submission said. “Depending on knowledge, education, experience, skill and curiosity, individuals with an interest in the kinds of hands-on, intellectually-challenging and technically-skilled work performed in all manner of aviation maintenance facilities may begin or continue a career through any one of the ‘pathways’ described in this AC.”
While the agency deliberates industry comment, schools are encouraged to download the community's work product to help illustrate the career paths available to would-be aviators.
The Federal Aviation Administration has published the long-awaited part 147 supplemental proposed rule for public inspection. The official version will publish in the federal register on April 16.
ATEC executive staff, board leadership and committee members will review over the next few days. Stay tuned for a full analysis.
Comments will be due 60 days after publication, which should fall on or about June 15.
The proposal is available at https://www.federalregister.gov/documents/2019/04/16/2019-06399/aviation-maintenance-technician-schools.
On April 11, the Aeronautical Repair Station Association (ARSA) received the FAA’s response to a Feb. 5 letter sent by a coalition of aviation organizations, including ATEC, regarding funding for the new aviation workforce development grant programs created by Sec. 625 of last year’s FAA reauthorization law.
Assistant FAA administrator for human resource management Annie Andrews stated that while the agency was committed to implementing the workforce development initiatives, there were no plans to begin before 2021.
An aviation coalition, led by ARSA, will continue to push for program funding in FY 2020 appropriations bills so the FAA can start making grants in FY 2020. The trade association is calling upon the community to make initiation of the grant programs a near-term priority for Congress and the FAA.
If your organization is in the district of a member of the House or Senate appropriations committees visit ARSA's action center to send a note in support of the initiative: arsa.org/legislative/grant-program-action-center.
Read the FAA's response in its entirety here: faagrantresponse-20190412.pdf
As reported in the recent ATEC Pipeline Report, 30% of A&P school graduates do not take the exam necessary to receive a mechanic certificate. Access to practical testing examiners was identified as one of the top barriers for students seeking FAA mechanic certification. An ATEC contingency recently joined FAA officials to discuss one possible solution to the testing bottleneck.
The agency is considering organization designation authorization (ODA) for practical testing. That means that a school (or other properly certificated entity) could create its own quality system to manage a group of designated mechanic examiners (DME), alleviating the need for FAA oversight of each individual DME.
The system would free up FAA resources while expanding the DME workforce. FAA officials in charge of the potential expansion to the existing ODA program will present more information at the upcoming ATEC Annual Conference.
For more information, see related story that published in the December edition of Aviation Week's InsideMRO, FAA Considers Organization Designation Authorization For Practical Testing.
As ATEC members well know, the FAA is in the process of replacing the Aviation Mechanic General, Airframe, and Powerplant Practical Test Standards (PTS) with a single Aviation Maintenance Technician (AMT) Airman Certification Standard (ACS).
This past spring, the agency published a draft version of the AMT ACS so stakeholders could familiarize themselves with the new document and provide feedback. At the June ACS working group meeting, committee members reviewed and incorporated the feedback. The latest rendition of the draft testing standard is available on the Airman Certification Standards issue page.
Until the standard is officially published, scheduled for June 2020, the AMT PTS (FAA-S-8081-26A, -27A, -28A) remains in effect; and applicants, instructors and evaluators should continue to use those documents for the oral and practical tests.
Stakeholders are welcome to submit feedback on the new draft document to email@example.com.
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.
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.
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.