Fourteen aviation groups are appealing to the FAA to take a less prescriptive approach as it updates standards for aviation maintenance technician schools (AMTS) under Part 147. Instead, the groups pushed for an outcomes-based approach in their jointly submitted comments to a supplemental notice of proposed rulemaking (SNPRM) that was released in April.
The agency originally issued a proposed rulemaking in 2015, saying current regulations and requirements are outdated and do not meet industry needs. After reviewing the initial comments, the FAA followed with the SNPRM to incorporate two changes requested by industry: to provide the option of competency-based training and satellite training locations.
But in the joint comments, industry groups are asking the agency to go further, including reconsidering prescriptive terms in the SNPRM. They further encouraged simplification of dual-enrollment programs and deference to the Department of Education requirements on issues involving quality of education.
“Fixing 147 is an industry imperative. Handicapping our schools burdens both graduates and employers,” they said. “Give us the flexible and dynamic rule needed to ensure we can educate the future workforce by the best means necessary.”
The joint comments—signed by the Aeronautical Repair Station Association, Aircraft Owners and Pilots Association, National Air Transportation Association, and National Business Aviation Association, among others—endorsed comments previously filed by the Aviation Technician Education Council (ATEC), which represents AMTS.
“The education community is in dire need of an outcomes-based regulatory approach, whereby schools have the flexibility to develop individualized programs that meet local employer needs,” ATEC told the agency. “Given the agency controls the standard, the mechanic test, and associated guidance material, it need not micromanage how an AMTS will ensure students are properly prepared to meet the standard.”
ATEC further stressed the need to adhere to the Department of Education standards. “Higher institutions of learning are overseen by accreditors that ensure educational outcomes are achieved through annual audits and regular oversight,” ATEC said. “The agency’s proposals duplicate—and often contradict—these accreditation requirements. ATEC asks that the agency focus its oversight on elements specific to a certificated aviation maintenance program that are not otherwise driven by DOE requirements.”
ATEC added it appreciates the agency addressing concerns regarding competency-based programs and satellite locations. But at the same time, the association expressed concerns that the SNPRM “layers in a complicated web of duplicative requirements and approvals for competency-based programs and satellite locations. The added elements would create more bureaucracy and disincentivize schools looking to expand reach to high schools and provide competency-based programs.”