On Aug. 5, ATEC and its sister organization, Choose Aerospace, joined AMFA, ARSA, AAR Corp., the Teamsters, the STEM Education Coalition, and the Universal Technical Institute, calling on President Biden to take specific action in support of aviation technical workforce development.
 
In its plea, the group cited the long-standing workforce crises that has only been exacerbated by the pandemic, and asked the administration to take the following actions:
 
(1) Increase funding for the FAA workforce grant programs
(2) Better facilitate military-to-civilian career transitions
(3) Support establishment of National Center for Advancement of Aviation (see S. 1752 and H.R. 3482)
(4) Support positive messaging about transportation careers (see S. 1681 and H.R. 3310)
 
The letter acts as a roadmap for the coalition's advocacy efforts moving forward, many of which align with ATEC's legislative priorities. Read the entire letter here.

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.

On Sept. 20, an aviation coalition continued its push to solve the aviation maintenance workforce crisis by helping the government to define it. The group, spearheaded by ATEC, filed comments asking the Standard Occupational Classification Policy Committee to revise aviation maintenance personnel definitions to more accurately reflect the aviation maintenance industry.

The SOC system is the source of all federal occupational statistics; it determines precisely which occupations exist and is used by government agencies to calculate and analyze wages and employment trends, supply and demand, and expected growth. The aviation maintenance industry has been stuck in a void – trapped under incorrect classifications – for years. Within the current system, nearly all aviation maintenance professionals are classified into a single occupation titled “Aircraft Mechanics and Technicians”, with a separate category for “Avionics Technicians”.

The alliance, including the Aeronautical Repair Station Association, the Aerospace Maintenance Council, Airlines for America, the Aviation Technician Education Council, the Cargo Airline Association, the General Aviation Manufacturers Association, Helicopter Association International, the National Air Transportation Association, a former member of the National Transportation Safety Board and the Regional Airline Association, asked that the two categories be replaced with three occupations: certificated mechanics, certificated repairmen and non-certificated technicians. The coalition argued that classifying workers using FAA certification is the most logical and useful method; since aviation safety rules use the same definitions to dictate precisely who is allowed to perform maintenance, preventive maintenance and alteration tasks.

For AMTS, a change in the classification structure would mean more precise wage and outlook information to help recruit potential A&P mechanics. Currently, federal occupational data for Aircraft Mechanics and Service Technicians and Avionics Technicians does not take into consideration whether the person has an A&P license. Theoretically, a change in the structure would reflect a higher starting pay for those with a mechanic certificate (as opposed to aviation technician positions that do not hold a certificate).

Reclassification, along with other planned improvements to the Department of Labor’s analysis tools, would also positively influence the “industry outlook” for aviation mechanics, which, according to O*NET OnLine, does not include rapid growth or a large number of job openings. A “bright outlook” categorization often determines whether a career counselor will recommend a career path, making the designation extremely important for the future aviation workforce.
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ATEC looks forward to working with our industry partners and government agencies to ensure the future of aviation maintenance is properly reflected as shiny and bright.

​After much work and determination on behalf of council members and FAA representatives (see previous story), the FAA part 147 aviation inspector training course is available to industry attendees. The registration fee for the in-person training, held at the FAA Academy in Oklahoma City, is $241.65. For instructions on how to enroll, visit https://av-info.faa.gov/DsgReg/sections.aspx?CourseID=409. If there is not a course currently scheduled, email ATEC to get on the waiting list.
 
The course prerequisite, FAA27100162, Intro to Part 147 Aviation Maintenance Technician Schools for GA Airworthiness ASIs, is available online for $150. Those who wish to attend the FAA part 147 aviation inspector training course in Oklahoma City are required to take the prerequisite in advance: https://av-info.faa.gov/DsgReg/Sections.aspx?CourseInfoID=384.

On June 15 the FAA released change 460 to the Flight Standards Information Management System, harmonizing inspector guidance with language in Advisory Circular (AC) 147-3B. The revision also institutes FAA inspector part 147 course attendance (also available to industry) and integrates the agency’s new compliance philosophy.

ATEC applauds the FAA for making needed revisions and adopting council-proposed language (see letters here, here and here). Further improvement can be made by removing continued reference to “makeup assignments” which ATEC maintains is not supported by the regulation.

Section 147.31(e) requires that AMTS show how missed material will be made available to students; FSIMS however states that “a student must complete all makeup assignments, class assignments, and exams missed in a module before an instructor can administer any written, oral, or practical test” and that “failure of a student to complete all makeup assignments and material within the school’s approved allotted time period may result in the student being required to repeat that subject” (see Vol. 2, Ch. 12, Section 2, paragraph 2-1449(G)). While some inspectors interpret the provision in the context of school policy and procedures, others seek to enforce prohibitive and prescriptive conditions that misallocate AMTS and agency resources. ATEC therefore requested that the provisions be removed in their entirety.

Even more concerning, the agency added a provision that “instructors cannot use the material from distance learning offerings to make up material missed from a classroom or lab offering, or vice versa.” While there are certainly limitations to what can be virtually taught (i.e., hands-on lab projects, etc.), the assumption that distance learning is substandard to “traditional” forms of teaching flies in the face of innovation, access to education and the good work of joint FAA/industry advisory committees. The manner in which material was originally taught should not dictate how it is subsequently made available, especially when technology provides the opportunity for unrestricted access.

ATEC will continually engage with its FAA counterparts to ensure internal government documents work in concert with the plain language of the regulation. Members are encouraged to submit feedback on this and other regulatory compliance matters to atec@atec-amt.org.

A red-lined document outlining the specific changes in FAA Order 8900.1, Vol. 2, Ch. 12, Section 1, Section 2 and Section 3 and Vol. 6, Ch. 10, Section 1 is available here.

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.

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/.

In a memo dated Feb. 10, the FAA issued a deviation to inspector guidance eliminating qualification parameters requiring Designated Mechanic Examiner (DME) applicants to “concurrently” exercise the privileges of a mechanic certificate while teaching at an AMTS.

Order 8900.2A, ch. 6, sec. 1, para. 1(a)(3) precludes the most experienced instructors from appointment because of the inability, either due to personal time restrictions or school policy, to pursue part-time employment while instructing at an AMTS.
​
ATEC requested the deviation in a Jan. 22 letter to the agency (see previous story), where the council maintained that the “immediacy” requirement creates an undue restriction without providing an increase in safety, and disqualifies many current DME and otherwise excellent applicants.
​
The agency did not adopt ATEC’s suggestion that inspector guidance be tied directly to similar requirements found in the regulation; specifically, § 65.83(a). Under that section, an AMTS instructor may satisfy recent experience requirements so long as the administrator deems that person “able to do that work.”
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To see more from ATEC on this issue, click here.

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.

On Jan. 22, ATEC submitted a letter requesting a deviation to experience requirements for Designated Mechanic Examiners (DME) found in Order 8900.2A. The overly restrictive language has created difficulties for those seeking and renewing DME designations across the country. Although the agency plans to release new inspector guidance (Draft Order 8000.95 CHG 2) this summer that will alleviate some concerns, many of the most experienced AMTS instructors will be ineligible for designation until then.
To see more from ATEC on this issue, click here.

On November 30, ATEC was notified that the FAA removed the 400 hour limit on distance education in Order 8900.1. This revision brings both internal and external guidance on this issue into conformity.

The council maintains, as it did in its comments to Draft Advisory Circular 147-3B, that distance learning instruction should not be limited by the number hours, but rather by subject matter and the technology available to ensure material is properly conveyed. The agency responded to ATEC’s pragmatic approach by removing the 400 hour limitation on distance learning instruction from the final language in the Advisory Circular.

Not to lose momentum, ATEC submitted a letter requesting the removal of the hours of instruction limitation from internal guidance as well. The FAA again responded favorably by removing the language from Order 8900.1. Agency personnel confirmed that part 147 inspectors would be immediately notified of revision.

ATEC’s success on this issue is a direct result of member engagement and persistence in advocating for ATEC members and the aviation community at large.

On Oct. 9, ATEC submitted comments on Draft Order 8000.95 CHG 2. The Order sets forth proposed revisions to the FAA’s Designee Management Policy.

ATEC’s board met with FAA officials in September to discuss the most vexing issues regarding the appointment of Designated Mechanic Examiners (DMEs) and the administration of the A&P exams. With regard to the appointment issue, current inspector guidance (i.e., Order 8900.2A) provides DME qualifications that eviscerate the DME corps by removing virtually every AMTS instructor’s eligibility for designation. Draft Order 8000.95, which will eventually replace DME provisions in Order 8900.2A, resolves some of these issues.

Under the new draft order, AMTS instructors with five years’ experience are qualified. Current language in Order 8900.2A providing that an AMTS instructor concurrently exercise the privileges of a mechanic certificate has been eliminated. This revision is essential to ensuring there are enough DMEs across the country and will hopefully facilitate appointment of new designees.

The remainder of ATEC’s comments focuses on the recentness of past experience prior to designation and the inability to examine more than one A&P applicant at a time. The council has taken the position that if a DME applicant has the requisite experience (e.g., five years performing maintenance under a part 145 certificate, exercising the privileges of a mechanic certificate or giving instruction at a part 147 school), it should not matter whether three of those years were immediately before designation.
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The Order is expected to go into effect early 2016.

On Aug. 1, ATEC’s business office hosted a teleconference with members of the council's board and FAA officials from the Regulatory Support Division (AFS-600). The topic of discussion was recent revisions to Order 8900.2, which impose new experience requirements for DMEs and prohibit designees from testing more than one A&P applicant at a time. 

The agency was surprised to hear that its revisions—which were meant to help the aviation maintenance industry—were actually hindering AMTSs from training qualified mechanics. 

The call was the embodiment of ATEC's strong relationship with the FAA and highlighted the benefit of direct engagement. ATEC and the agency agreed to work together on the matter by exchanging information concerning the supply of DMEs, testing protocols, guidance for FSDOs and upcoming revisions to Order 8900.2A. 

Stay tuned as the council continues to work the issue.

 

Tim Shaver, the acting manager of the Aircraft Maintenance Division, participated along with ATEC's Business Manager Crystal Maguire and board member Chuck Horning, department chairman of aviation maintenance science at Embry Riddle University. At the completion of the recorded session, participants will understand:

1. What are OpSpecs?
2. When will OpSpecs be issued? (Answer: They should have been issued by July 21!)
3. How are OpSpecs maintained?

What:
Operations Specifications Webinar Recording

Who:               
Crystal Maguire, ATEC
Chuck Horning, Embry Riddle University
Tim Shaver, FAA

Price:             
$10.00

Registration:
Click here to access the recording.

On August 10, ATEC submitted a letter to the FAA regarding FAA Order 8900.2A – Revisions to A&P Examination Procedures and DME Appointment. To read the submitted letter, click here.

Original post from 07/10/2015:

On July 10, ATEC submitted a letter requesting the agency rethink its new guidance regarding the administration of the A&P exams and the appointment Designated Mechanic Examiners (DME). More specifically, Order 8900.2A eliminates the exception for DMEs to test multiple applicants at a time when there is a “valid need.” By removing this exception, the number of examinations will multiply and the difficulty scheduling exams will be exacerbated by the administrative burdens associated with transitioning to computer-generated test questions/projects. 

Additionally, Order 8900.2A revises the qualifications required for AMTS instructors to be appointed as a DME. Under the revised guidance, AMTS instructors not only must have been an instructor for the preceding five years, but they must also have exercised the privileges of their A&P certificate for three years. This additional qualification serves no other purpose than to add a barrier to entry and to prevent some of the most experienced academics from providing examinations.

ATEC has given the agency a chance to reconsider and revise the order accordingly.

On Aug. 3, ATEC submitted a letter to the Federal Aviation Administration (FAA) formally requesting the agency’s academy course for inspectors of part 147 schools be made available to industry.

ATEC members have long been involved in the development of a course for inspectors who perform certification and surveillance of aviation maintenance technician programs (see previous story). Indeed, ATEC representatives attended the inaugural course in October 2014; unfortunately, it has not yet been offered again.

The letter encouraged the agency to make the course more widely available to both FAA officials and industry representatives. Ed Hall, a long-time ATEC supporter and advisor to the Aviation Institute of Maintenance, spearheaded the effort: “The council worked hard to help develop the course content, but the work doesn’t stop there,” Hall said. “Industry needs to keep pushing to ensure the material is accessible and continually improved to further regulatory standardization and understanding.”

The council offered to partner with the agency to make the content more widely available through its online training platform and stands ready to work alongside the agency on this important effort.

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 July 10, ATEC sent a letter to FAA headquarters concerning recent changes to FAA Order 8900.1 (“FSIMS”), Vol. 2, Ch. 12, Section 1 and Section 3 and Advisory Circular (AC) 147-3B (see previous story http://www.atec-amt.org/member-alerts/-faa-updates-fsims-for-amts-certification-and-evaluation). In its letter the council requested revision to provisions regarding distance education and the availability of missed material.

Most of the language contained in FSIMS (directed at FAA inspectors), conflicts with the AC language (directed at industry). Most notably, the order contains guidance that would “limit” distance learning instruction to 400 hours of level one instruction, a provision that was removed in the final version of AC 147-3B (as recommended in ATEC’s comments to draft AC 147-3B).

Similarly, inspector guidance for implementation of § 147.31(e), which requires that the AMTS system “show hours of absence allowed and how missed material will be made available to the student,” is not consistent with AC 147-3B or part 147. The order’s language goes beyond the scope of the regulation, specifically “requiring” that all missed projects and assignments be “made up” and the manner in which that must be accomplished.

In its letter the Council also requested some edits to AC 147-3B to ensure consistency and to clarify ambiguities in that recently-revised document.

On June 4, a coalition of aviation trade associations took the first step towards solving the aviation maintenance workforce crisis by helping the government to define it. The group, spearheaded by ATEC, asked the Standard Occupational Classification (SOC) Policy Committee and the Office of Management and Budget (OMB) to revise the SOC system to more accurately reflect the aviation maintenance industry.

A broad alliance, including the Aeronautical Repair Station Association, the Aerospace Maintenance Council, Airlines for America, the Cargo Airline Association, the General Aviation Manufacturers Association, the National Air Carrier Association, the National Air Transport Association,  the Regional Airline Association and a Former Member of the National Transportation Safety Board, joined ATEC in submitting comments to the SOC revision process, the results of which are set for implementation in 2018.

The SOC system provides the framework for all occupational statistics collected and disseminated by federal agencies. For federal statistical purposes, it determines precisely which occupations exist and has a significant impact on the legislators, educators, employers and job seekers who utilize that data. The aviation maintenance industry has been stuck in a void – trapped under incorrect classifications – for years. Within the current system, nearly all aviation maintenance professionals are classified into a single occupation titled “Aircraft Mechanics and Technicians.”

The group requested that this lone category be replaced with three separate occupations: certificated mechanics, certificated repairmen and non-certificated technicians. Classifying workers using FAA certification is the most logical and useful method; since aviation safety rules use the same definitions to dictate precisely who is allowed to perform maintenance, preventive maintenance and alteration tasks.

Along with a requested clarification of the “Transportation Inspectors” category, the submission proposed elimination of “Avionics Technicians” as a distinct category. These professionals should be tracked based upon certification, ATEC and its allies contend, just like every other aviation maintenance worker.

“Data empowers organizations to make sound decisions,” says Ryan Goertzen, ATEC President, “With Today's SOC structure we can't build a world class work force because the data is unreliable and inaccurate to capture our industry needs.”

ATEC surveyed all aviation maintenance technician schools (AMTS) holding an FAA part 147 certificate in order to assess key trends in the industry and gather data about both student and institutional needs in order to plan future council programs and initiatives.

The survey period closed on Jan. 16, 2015. Out of the 172 AMTS contained in the FAA certificate database, 54 responded – nearly one third of the entire population. This strong participation rate makes the survey a reliable snapshot of the AMTS community.

Take a look at that picture; view an infographic of the results by clicking the image below.

On Feb. 15, ATEC submitted comments to draft Advisory Circular 147-3B. The AC provides guidance to part-147 aviation maintenance technician schools on curriculum and operating requirements.

A working group consisting of school representatives prepared the comments on ATEC’s behalf. Members of the working group included--

·         Fred D. Dyen, Professor & Coordinator, Aviation Maintenance Technology Program, Blue Ridge Community College
·         Ryan Goertzen, President, Spartan College of Aeronautics and Technology
·         Paul Herrick, Professor, Aviation Maintenance Technology, University of Alaska Anchorage
·         Kevin High, Associate Professor, Western Michigan University College of Aviation
·         Charles E. Horning, Department Chairman, Aviation Maintenance Science, Embry-Riddle Aeronautical University
·         Shannon McGurk, Corporate Director of Education, Aviation Institute of Maintenance
·         Andrew Smith, Associate Professor, Aviation Maintenance Management, Kansas State University

The group’s comments suggested several modifications to the draft AC. Generally, the comments sought to ensure consistency with regulatory requirements and that the AC provides best practices and guidance as opposed to imposing new requirements. Specific recommendations included--

·         Rewrite of the proposed appendix 11, addressing distance learning, including rejection of the 400 hour limit “imposed” by the AC.
·         Modifications to operations specifications sections to ensure consistency with WebOPSS program.
·         Removal of the question and answer (Q&A) appendices; specifically, Appendix 3 Frequently Asked Questions Regarding AMTS Certification and Operation and Appendix 4 Frequently Asked Questions Regarding AMTS Operations Specifications. The group noted that the Q&As are outdated and better suited for an online webpage where they can be frequently updated and revised.
·         Rewrite of “missed material” section to ensure clarity of regulatory requirements (i.e., missed material availability vs. makeup time).
·         Addition of paragraph encouraging dual-enrollment programs with accredited educational institutions.
·         Rewrite of Appendix 12, “Letter of Compliance” such that it would provide a reference for both industry and government to ensure an institution’s compliance with the regulation.

The working group’s submission package is available for review at http://www.weebly.com/uploads/1/0/7/5/10756256/atec-ac147-3b-commentsubmission-web-20150214.pdf. 

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.

On Jan. 21, ATEC and the Aeronautical Repair Station Association (ARSA) submitted joint comments on FAA Draft Advisory Circular (AC) 65-25F, “William (Bill) O'Brien Aviation Maintenance Technician Awards Program.”

The O’Brien Awards
Through the William (Bill) O’Brien Awards Program, the FAA recognizes eligible technicians who receive and businesses that promote professional development. The program was founded in 1991 to create an incentive for AMT employees and employers to participate aggressively in maintenance training courses.

Updating AC 65-25
The agency’s purpose for updating the AC was to provide a general overview of the program and direct potential participants online for further information. To ATEC and ARSA, the update represents an opportunity to improve the document in other ways. Most notably:

(1)  Adding part 147 Aviation Maintenance Technical Schools (AMTSs) to the list of acceptable instruction or course providers. Individuals should be encouraged to take refresher courses from these FAA-controlled institutions. For their part, the schools should have an incentive to provide classes (and many do as IA renewal seminars) that do not meet the definition of “college level course” in the AC.

(2)  Removing the three-employee requirement from eligible companies. Any company that engages in aviation services should be supported by this program, no matter the size.

To view the entire submission, including a suggested version of the AC with red-lined changes, please click here. 

On Dec. 10, the Aeronautical Repair Station Association (ARSA) and the Aviation Technician Education Council (ATEC) jointly submitted a re-write of Federal Aviation Administration (FAA) Advisory Circular (AC) 65-30B: “Overview of the Aviation Maintenance Profession.”

The agency solicited input on the draft AC, which had been revised to include updated maintenance career information and details about military to civilian occupational transfers. As the world’s leading voices for aviation maintenance training and employment, ARSA and ATEC completely overhauled the circular.

“To ensure the government can do its job, we did ours,” said Sarah MacLeod, ARSA’s executive director. “A coalition worked to ensure the AC created an informational resource for the entire aviation maintenance industry; a blueprint for American workers to build a rewarding, valuable career. We invested the hours so the aviation technical community can benefit for decades.”

The trade associations had jointly requested an extension of the original Sep. 10 comment submission deadline. ARSA and ATEC used the time to construct a comprehensive document with references to appropriate regulations, career resources including trade organizations, labor and private industry group resources.

“Our submission tells a compelling story,” said Ryan Goertzen, ATEC’s president as well as president of Spartan College of Aeronautics and Technology. “Aviation maintenance is an innovative, dynamic, prestigious industry that provides employment and careers with potential for limitless growth. Mechanics, technicians, specialists and repairmen enjoy more than competitive pay and interesting work; they guarantee the safety of the flying public worldwide.”