FAA Part 147 Supplemental Rule

Last month, the agency published the long-awaited supplemental notice of proposed rulemaking (SNPRM) for Title 14 CFR part 147, the regulation governing aviation maintenance technician schools.

The proposal "supplements" the agency's 2015 notice of proposed rulemaking, which recommended removal of static curriculum requirements and allowance for a credit-hour system. ATEC and others called for more flexibility that would allow for competency-based programs and expansion of curriculum into high schools. The SNPRM makes additional proposals to address those concerns.

While the community applauds the agency for offering a solution, elements in its proposal miss the mark. The SNPRM layers in a complicated web of requirements and approvals for competency-based programs and satellite locations, many of which duplicate accreditation mandates.

In its comments to the SNPRM, the council will reiterate its plea for FAA deference in all matters concerning the quality of education, an element that falls squarely in the Dept. of Education's purview. It will ask that the agency focus its oversight on items specific to a certificated A&P program, such as facility, equipment, and material requirements, unique instructor qualifications, and assessment based on student performance of the mechanic test.
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It is ATEC's position that accredited higher institutions of learning not be subject to duplicative--and sometimes contradictory--government requirements. The Dept. of Ed and its accrediting bodies are the education experts, and work in partnership with our schools to ensure educational outcomes are achieved. The council's comments to the SNPRM will be grounded in that theme, and offer alternative language that gives our schools more flexibility, and puts less burden on our stewards of aviation safety.

ATEC's docket submission will be available to the community in advance of the comment period deadline, so that stakeholders can align with the council's stance in their own comments, if they so choose.

For a full analysis, read an article that ran in the latest edition of Aviation Week's Inside MRO, Proposed Regulation Raises Questions About FAA’s Role In Education.

To brief the community on the particulars, and assist schools and companies with their own comments (due June 17), the council is holding an online webinar on May 30. The online event is free to government employees and ATEC members.