ATEC Submits Comments to Part 147 SNPRM

In a June 12 submission, ATEC voiced its feedback to the latest FAA rule making regarding aviation maintenance technician schools.

The comments, a committee-run work product that took three months and more than ten conference calls to create, push back on what the council says would create an overly-prescriptive system and stifle an already inadequate mechanic pipeline.

The submission calls for FAA deference in all matters concerning the quality of education, an element that falls squarely in the Department of Education's (ED) purview. As further explained in the comments, "Higher institutions of learning are overseen by accreditors that ensure educational outcomes are achieved through annual audits and regular oversight. The agency’s proposals duplicate—and often contradict—these accreditation requirements."

The council also reiterated it's plea for an outcomes-based approach, one that would utilize new mechanic airman certification standards as the basis for curriculum, and negate the need for the agency to micromanage schools through curriculum approvals and hour requirements.

Finally, the council offered an alternative to the satellite system proposal set forth in the supplement. It suggests a simplified approach that would allow AMTS to include "additional fixed locations" on their operations specs, consistent with processes for other air agencies. The familiar scheme would allow schools to provide content at local high schools and support dual enrollment programs, so long as the "additional fixed location" met the requirements of part 147. Indeed, as the council stated in its comments, the agency could implement this opportunity even before a formal rule change.

Read the council's comments in their entirety here: https://www.atec-amt.org/uploads/1/0/7/5/10756256/atec-147snprm-faa-2015-3901-comments-20180612.pdf