On April 18, ARSA submitted supportive comments to the Federal Register notice related to a Southern Utah University petition for exemption from the curriculum requirements of Title 14 Code of Federal Regulations (CFR) § 147.21(a)-(c).

SUU is an accredited member of the Northwest Commission on Colleges and Universities and an ARSA educational member. The school is planning to expand its existing aviation program – it offers an Associate of Applied Science in Aviation for both fixed and rotor-wing pilots – to include aircraft maintenance technician (AMT) training. The new program would be developed using the school’s credit hour system to administer the emerging AMT Airman Certification Standards (ACS) as the basis for it’s A&P curriculum.

ARSA’s comments highlighted how granting the exemption would allow the FAA to gather insight regarding not only the planned ACS but also the agency’s efforts to rewrite part 147. While developing larger policy the agency could observe the effectiveness of an independent program while relying on its existing rules for airman certification to ensure an equivalent level of safety.

“In short, the regulatory system provides a layered structure of requirements for an individual to gain and maintain authority to perform and approve work for return to service,” the submission said. “The FAA possesses multiple points of oversight through which to ensure safety.”

In addition to supporting regulatory progress, ARSA recognized the public interest identified by SUU in its petition: The pressing need to increase available technical talent. Referencing its own data on both technician onboarding and the industry-wide costs of the aviation workforce shortage, the association encouraged the FAA to “take advantage of any opportunity to support improvement in AMT education.”

To read the full submission, click here.

To review the Federal Register docket, click here.

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