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Continuing Call for Competency in Part 147

On June 17, ARSA joined thirteen of its aviation allies on joint comments to the supplemental notice of proposed rulemaking (SNPRM) related to 14 CFR part 147.

The coalition echoed comments previously submitted by the Aviation Technician Education Council (ATEC), asking the agency to reconsider prescriptive terms and pushing for an outcomes-based approach to its regulatory oversight of aviation maintenance technician schools (AMTS). The group reiterated the need for a simplified approach to dual enrollment programs and deference to Department of Education requirements for matters concerning the quality of education.

“Fixing 147 is an industry imperative,” the letter said. “Handicapping our schools burdens both graduates and employers. Give us the flexible and dynamic rule needed to ensure we can educate the future workforce by the best means necessary.”

In addition to ARSA, the following organizations signed the letter:

Accrediting Commission of Career Schools and Colleges
Aerospace Maintenance Council
Aircraft Mechanics Fraternal Association
Aircraft Owners & Pilots Association
Airlines for America
Aviation Technician Education Council
Cargo Airline Association
International Air Transport Association
National Air Carrier Association
National Air Transportation Association
National Business Aviation Association
Professional Aviation Maintenance Association
Regional Airline Association

To read the joint comments, click here.

Previously from ARSA...

2/3/16 - Part 147: Aviation Industry Stands Up for Competency

February 3, 2016

On Feb. 1, ARSA joined a broad effort to get the new 14 CFR part 147 – the long awaited update to the rule governing aviation maintenance technician schools – right. The association united with 13 other organizations, including Airlines for America, the Aviation Technician Education Council and a broad swath of aviation, maintenance and educational interests to demand the FAA produce a competency-based final rule.

The group submitted comments to the agency’s notice of proposed rulemaking (NPRM) to update part 147. The submission decried the NPRM’s continued reliance on class time at the expense of technical capability.

“Put simply, the proposal would impose 20th century educational practices on a 21st century industry,” the group said. “It maintains its predecessor’s antiquated concern with the time a student spends in a classroom seat rather than focusing on the skills he or she actually gains. A competency-based standard, free of defined schedules and specific hour requirements, will allow industry to transition away from seat time in favor of a structure that creates flexibility and allows students to progress as they demonstrate mastery of subject matter, regardless of time, place, or pace of learning.”

By sending a single message to the FAA, the group demonstrated industry-wide commitment to supporting A&P schools. Broadly calling for emphasis on technical capabilities over classroom hours allowed the association’s educational allies – particularly ATEC – to focus on building a structure that would allow institutions to adhere to regulatory standards while tailoring programs to meet industry needs.

“Industry has suffered the repercussions of an outdated rule for far too long,” ATEC’s separate comments said. ““[Aviation maintenance technician school] students have been forced to spend wasted effort and time learning antiquated skills, and industry has borne the cost. We desperately need a competency-based rule that gives educators flexibility to teach the future workforce the skills needed to support the ever-changing, technology-driven, dynamic aviation industry.”

Getting part 147 right is vital not just for education institutions, but for the aviation businesses that depend on their product – qualified, technically skilled technicians. ARSA will continue to support the effort to develop a rule that enables effective schools to grow competent students that serve a flourishing aviation community.

To view the combined industry comments, click here.

10/27/15 - Aviation, Education Groups Request Time to Help Get 147 Right

October 27, 2015

On Oct. 26, a team of aviation and education industry groups requested an extension to the comment period for the FAA’s proposed update to 14 CFR part 147. The group requested more time to consider and analyze the long-awaited notice of proposed rulemaking (NPRM) to help the agency produce an effective final rule, which has not been substantively updated since the 1970s.

The effort, led by the Aviation Technician Education Council (ATEC), was supported by representatives from aviation groups and technical education interests. In addition to ARSA, the submission was signed by:

Aerospace Maintenance Council
Aircraft Electronics Association
Aircraft Owners and Pilots Association
Airlines for America
Aviation Suppliers Association
Helicopter Association International
Modification and Replacement Parts Association
National Air Carrier Association
National Air Transportation Association
Regional Airline Association
STEM Education Coalition
University Aviation Association

“[The final rule will impact] not only the hundreds of institutions that educate our workforce, but also the thousands of businesses that rely on AMTS graduates to keep aircraft in flight,” the group explained. “With the additional time requested, the aviation industry and its partners in technical education will help the agency develop a rule that supports schools, aids students at the beginning of a rewarding career and serves an important and growing industry.”

As the agency reconsiders the deadline, interested parties can now focus on substantive comments. Stay tuned…



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