ARSA filed comments with the FAA supporting Blue Ridge Community College’s (BRCC) efforts to modernize the requirements for aviation maintenance training at schools licensed under 14 CFR part 147.

BRCC, a part 147 certificated institution offering an associate degrees in aviation maintenance technology, recently filed a petition for reconsideration to the Federal Aviation Administration (FAA). The original petition requested that BRCC be allowed to alter its program curriculum to keep up with changes in aircraft technology. The FAA rejected BRCC’s original petition, maintaining that the current distribution of hours continues to ensure industry and safety needs; ironically relying on industry feedback received in the early 1980s.

In its reconsideration petition, BRCC argued that curriculum requirements have changed little since first promulgated in 1962 and the hours of instruction distribution no longer reflects the standard to which maintenance technicians must work. The mandated hours of instruction vis-à-vis the mandated subjects and items inhibit voluntary enhancement of those standards. Redistributing the mandated hours to reflect the demands of modern industry would allow BRCC and similar programs to provide the safety and educational training the requirements originally intended to produce.

ARSA’s comments strongly support BRCC’s contentions and the Association agrees that the current curriculum mandates under part 147 are outdated and hamper technician schools’ efforts to provide industry with personnel that are familiar with new and changing aircraft technology. The Association takes issue with the FAA’s statement that “the hours of instruction, as a minimum, contained within 14 CFR § 147.21 continue to prepare a student to meet…training standards as sought out by industry.”

Allowing BRCC to redistribute mandated curriculum hours would ensure the institution remains competitive while allowing it to teach students skills that match current industry demands. Since there are no indications that a proposed rule revising the outdated curriculum requirements in part 147 is forthcoming, a petition for exemption from the rule is the only relief available.

BRCC also requested that the appeal be published and made available for comment (the original petition was not published), so that industry could have the opportunity to weigh in. In response, the FAA published the appeal in the Federal Register for public comment, which are currently being reviewed.

~~~ posted 8/22/12 ~~~

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