In September, ATEC sent a written request providing a proposed solution that would allow aviation maintenance technician schools to create more streamlined partnerships with other educational institutions.
In its letter, ATEC suggested that the FAA dispense with its continued reference to “satellite locations,” something the agency says is “prohibited” under the regulations. Instead, 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.
In its response, the FAA doubled down on its position that part 147 prohibits an AMTS from providing courses at an additional training location, “the current regulations in part 147 do not expressly allow for nor facilitate the use of satellite training locations by evidence of the FAA’s intent to allow an AMTS to have a single location.”
The conclusion suggests the agency misunderstood ATEC’s request. ATEC did not ask for the FAA to allow for an AMTS satellite location, it asked that the FAA take a new approach through utilization of operations specifications, one that would not require formal rulemaking and allow greater flexibility and bypass widespread confusion that will undoubtedly arise if the agency’s regulatory proposals in the part 147 NPRM and SNPRM come to fruition.
ATEC’s September letter was followed by extensive in person discussions with regulators at its annual Fly-in. Even given the seeming agreement with ATEC’s position at that time, the agency has refused to implement—or even properly address—ATEC’s proposed solution.
In ATEC's most recent member survey, FAA-imposed limitations was cited as one of the top barriers to development of AMTS-high school dual enrollment programs.
ATEC will not be deterred. Indeed, if passed, the PARTT 147 Act would force agency adoption of the proposed framework, despite the reluctance. That bill continues to garner additional support from legislative leaders, following recent visits to the Hill from a group of ATEC representatives. Join the effort, contact your representatives and encourage them to support the bill.
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