Industry has faced a tough workforce development challenge over the last few decades: keeping up with innovation while complying with decades-old curriculum requirements for aviation maintenance technician schools (AMTS). Industry, through the Aviation Technician Education Council (ATEC), has and will continue to provide encouragement, recommendations, and resources to ensure it is part of the solution.
A Brief History: Stuck in Time
AMTS curriculum requirements were originally established under the Civil Aviation Administration and re-codified into Title 14 Code of Federal Regulations in 1962. Since that time, the regulations mandating hours of instruction and curricula subject areas have not significantly changed.
During the same period of time, the design regulations mandating the standards to which a civil aviation article must be certificated and maintained have changed innumerable times (see regulatory history of parts 23, 25, 27, 29, 33, et. al.). These revisions have enhanced safety significantly; they also mandate more sophistication and knowledge in maintenance personnel (see § 43.13 which requires maintenance personnel to return civil aviation articles to at least their original or properly altered condition in accordance with methods, techniques, and practices provided in manufacturer maintenance manuals).
Outdated Curriculum, Unemployed Students
Both industry and government agree that outdated Part 147 requirements inhibit maintenance technician schools from keeping up with changes in aircraft technology. Indeed, in a 2003 report to the House Transportation and Infrastructure Committee’s ranking member, the U.S. Government Accountability Office called for updates to curriculum requirements:
… the required curriculum at aviation maintenance technician schools does not fully prepare A&P mechanics to work on commonly flown, technologically advanced commercial aircraft … today’s modern aircraft require A&P mechanics to have a different set of skills than those being taught at aviation maintenance technician schools. Since A&P mechanics that are newly graduated from aviation maintenance technician schools lack the skills to work on modern aircraft, officials at some major airlines said they are reluctant to hire them directly from school.
Sending the Regs to Reform School
In 2008 an Aviation Rulemaking Advisory Committee’s Aviation Maintenance Technician Schools Curriculum and Operating Requirements Working Group, consisting of industry and FAA representatives, issued a December report stating:
With changes in technology, it is believed that a static minimum curriculum does not meet broad industry needs. Approved training providers have the ability, within the current rule, to add additional hours and content beyond the minimum requirements. However, this can be an economic detriment and on occasion not been allowed by Principal Inspectors (PI)’s in the belief that the specified curriculum must be rigidly adhered to.
Thus, in its 2008 report the industry working group, chaired by past ATEC president Raymond Thompson, made 11 policy recommendations:
- Develop operations specifications for AMTS holding a Part 147 certificate.
- Update Part 147’s curriculum requirements found in the rule’s appendices A, B, C, and D.
- Create a maintenance training review board to ensure regular review of AMTS curriculum.
- Redistribute required training hours specified in 147.21(b).
- Include Part 147 institutions in FAA draft advisory circular (AC) “Alternatives to Classroom Training.”
- Clarify terms, definitions, and processes in 147.31.
- Revise 147.35 so that the general curriculum written examination can be completed prior to commencement of airframe and/or powerplant curriculum.
- Create a Part 147 surveillance course for FAA inspectors.
- Review and update AC 147-3, Certification and Operations of Aviation Maintenance Technician Schools.
- Update the practical test standards and knowledge test.
- Update Order 8900.1 to ensure consistency with revised rules.
ATEC’s Syllabus for Change
The last few months has brought a whirlwind of rulemaking activity, much in response to these 2008 recommendations.
The agency’s first AMTS inspector academy course was held this past October. ATEC helped develop the content and was invited to participate in the course (read more in ATEC’s November 2014 newsletter).
On Dec. 10, ATEC and the Aeronautical Repair Station Association (ARSA) jointly submitted a re-write of FAA draft Advisory Circular (AC) 65-30B, “Overview of the Aviation Maintenance Profession.” The concerted effort will ensure an informational resource for the entire aviation maintenance industry and will always be available on ATEC’s website, even if the agency does not adopt the re-write.
The agency is currently soliciting comment on draft AC 147-3B, Certification and Operation of Aviation Maintenance Technician Schools. The draft document adopts some of the working group’s recommendations that can be implemented prior to formal rule change, including distance learning and operations specifications guidance. ATEC believes the AC doesn’t go far enough in many areas and looks forward to providing extensive comment.
Finally, the agency has released a notice introducing operations specifications (OpSpecs) for AMTS which provides a standard OpSpecs template that will be used to control definitions and curriculum currently found in Part 147 appendices A, B, C, and D. ATEC has offered up its resources to ensure a smooth OpSpecs transition for industry and government alike.
ATEC expects the agency to issue a Part 147 notice of proposed rulemaking in the first quarter of 2015, shoring up the list of “to dos” provided by the industry working group. ATEC pledges to continue working with government and industry to ensure AMTS are able to provide qualified technicians to support the next generation of aviation innovation. Stay tuned!
Ryan Goertzen is the president of Spartan College of Aeronautics and Technology in Tulsa, OK. He was named president of the Aviation Technician Education Council in April 2014. To learn more about ATEC, visit http://www.atec-amt.org.
