It was a dark and dreary night.
Frustrated, I stared at the wiring diagram in my Basic Electronics textbook. Something was causing a severe roadblock to my understanding of the concepts. I felt inept, and feared I would never pass this required course for the general portion of my studies. Working the second shift in line maintenance, we had some downtime between flights. It was an excellent opportunity to catch up on homework for my Airframe and Powerplant (A&P) classes. But on this night, I was not getting it. Perhaps I could transfer to the ramp, work stores, or spend eternity as a helper. I needed help.
Help was right around the corner. Seeing me struggle, a co-worker approached me and asked if he could take a look. I slid the textbook over to him and continued searching for the newspaper “want” advertisements for a delivery truck driver. Not that there’s anything wrong with that.
“What did you do in the Navy?” he began.
“Sheet metal at first, but then transitioned to hydraulics,” I replied.
Grabbing a pen, he opened up a napkin and began to sketch. Roughing out a series of lines, circles, and triangles, he turned it around and asked me what I thought. I stared at the paper and blinked a few times, stumped. Next, he assigned labels to the shapes. Under the thin line, he scribbled “rigid hydraulic tubing,” next was the circle, “hydraulic pump,” and finally, under the triangles, “valve.”
Ok, that’s great, Dan. You drew a hydraulic schematic—big deal.
He scoffed as if to say, “OK, tough guy.” Next, he drew a slash beside each word and wrote “wire” beside tubing, “power supply” beside the pump, and “solenoid” adjacent to the valve. Bingo.
Learning is a lifelong process. Sometimes you get it. Other times you need a little help. Because of this lesson, I still refer to a wire as an “electron hose” to this day.
Two weeks ago, we discussed the path to becoming an A&P mechanic, and I mentioned changes to 14 CFR Part 147 Aviation Maintenance Technician Schools. This week, we are diving deeper into understanding what those changes are and how they affect aviation maintenance training moving forward.
Change Is Here
FAR Part 147 provides guidelines and is the law of the land for aviation maintenance technician schools (AMTS). Until recently, aviation maintenance schools’ guidelines were over five decades old. Just imagine the changes, obsolescence, and innovations since the original rules were written.
Billy Nolen, Federal Aviation Administration (FAA) associate administrator for aviation safety, announced at the 2022 Aeronautical Repair Station Association (ARSA) conference that change was upon us. Finally.
The Advisory Circular AC No: 147-3C Subject: Certification and Operation of Aviation Maintenance Technician Schools was published in March 2022. The FAA distributes advisory circulars as a roadmap to assist aviation entities in gaining and maintaining compliance.
In May, the FAA published an interim final rule and a request for comments regarding its new rule modernizing training requirements for aviation Part 147 schools. The new rule took effect September 21.
Mechanic Airman Certification Standard (ACS)
The Mechanic Airman Certification Standard (ACS) is the standard that drives the content for the new Part 147 rule. ACS bridges the gap between academics and industry and communicates instruction guidelines that students learn and upon which they will be tested.
In driving the curriculum and test, the ACS constantly reviews the content to maintain relevance and stay aligned with the industry. A dedicated working group will constantly review, evaluate, and adjust the ACS. It is important to note that the ACS also revamped the A&P test.
One organization stands out as a driving force behind the new 147 rule and the ACS. The Aviation Technician Education Council (ATEC), which provides representation, information, expertise, networking opportunities, online tools, and more to the aviation maintenance industry. The leaders of ATEC play a prominent role in the new 147 rule and are a wealth of information concerning the topic.
The new Part 147 is performance-based, with a strong emphasis on student exam scores. While this is by no means an exhaustive list, here are a few key points about the new look of Part 147:
- There are no seat-time or credit- hour requirements (previously it was 2,000 hours). This adjustment allows for competency-based programming.
- Curriculum approval is no longer required per 147; however, schools must show that the curriculum aligns with the ACS.
- Nationally accredited institutions takeover from the FAA regarding details such as establishing:
- Teacher-student ratios
- Grading systems
- Number of instructional hours
- Competency determination
- Delivery method
- Non-accredited institutions must have an FAA-approved quality system.
- For nationally accredited schools, the FAA will transfer governance of educational elements to the appropriate department of education (DOE)
- Freeing the FAA from curriculum approval takes them out of the classroom.
- Distance learning oversight comes from the academic accrediting body, not the FAA. Students can train off-site and away from a fixed location.
- Dual enrollment at a local high school is now possible.
- This opens potential expansion of online training
- The FAA will assess a program’s quality based on students’ testing results and a three-year rolling reporting mechanism. This will include oral, written, and practical testing.
- Still certificated by the FAA, schools will need to produce quality students or risk losing their certification.
The FAA will retain oversight of the following areas:
- Facilities
- Materials
- Equipment and tooling
- Instructor qualifications and experience
- Student-to-instructor ratio for the shop environment (currently 1 to 25)
- Quality system for non-federal accredited institutions
- Ensure curriculum alignment with the ACS
To comply with the new rules, schools must take the following steps:
- Perform a gap analysis and match current content against ACS
- Obtain new FAA-issued operations specifications (OpSpecs) to comply with the new rule and guide to do so.
- The accrediting body which approves programs and delivery methods remains constant.
Crystal Maguire, executive director of ATEC, was kind enough to spend some time with me and discuss how Part 147 finally came together.
FLYING Magazine (FM): How did we finally get here after all these years?
Crystal Maguire (CM): We started in 2009 and kept moving forward. The FAA was very supportive from the beginning. We worked closely with Tanya Glines, aviation safety inspector, Office of Safety Standards, to make this a reality.
FM: It is quite an accomplishment. What makes you proud?
CM: My favorite aspect of the new 147 is moving to a performance-based rule. We gained tremendous efficiencies getting the FAA out of the classroom.
FM: So, what is coming next?
CM: The Designated Mechanic Examiners (DME ) ranks are getting up to speed for testing next summer. The industry is facing capacity issues and needs to shore up its positions.
Another exciting project is the development of a high school curriculum to prepare potential A&P students called Choose Aerospace. The goal is to give students the ability to take their general test right out of school. This progress will provide them with a head start on certification.
Collaboration
What does collaboration mean for aviation technical schools moving forward?
In the past, the FAA held sway over course content and had to review and approve it. Now that course curriculum is no longer in the rule, this opens up relationships between schools and companies. Under the new guidelines, schools can update course content as needed.
Because of the locked content, if a school wished to highlight a specific topic or focus on a particular subject outside the established curriculum, they had to add additional classes for that topic. Therefore to add more industry-specific content, schools had to expand their programs. The result was more time and additional cost.
Under the new 147, schools can incorporate partner-specific content into their curriculum. One example is industry powerhouse AAR partnering with WSU Tech that “will expand the curriculum of WSU Tech’s aviation maintenance technology program.” AAR and other business entities are vested in the aircraft mechanic pipeline, especially in light of the looming mechanic shortage.
Some companies are already feeling the pinch of a labor shortage. A recent Boeing study predicts demand for 193,000 new mechanics in North America through 2037.
Spartan College of Aeronautics and Technology established a relationship with SkyWest Airlines, which “engages the student much earlier than traditional partnerships” with mentoring by SkyWest mechanics.
I spoke with Adon Clark, dean of the School of Aviation at Middle Georgia State University, concerning his thoughts on the new 147.
“It allows for more academic flexibility to meet the industry’s and our students’ needs,” Clark said. “It added new teaching requirements to better prepare our students for the industry. It will also provide an easier process to establish satellite-training locations, in the past, that would require a full Part 147 certification.
When I inquired how the new change was going, Clark replied, “It is still very new, and we will see how the process goes.” We also discussed how the end goal is a better aviation labor pipeline.
This new rule will not impact FAR 145 certified repair station programs or individual airlines/entity training systems.
The bottom line is the industry needs A&P mechanics, not individuals from an A&P school who never tested. The hope is that the new more flexible Part 147 will help alleviate the skilled aircraft maintenance personnel shortage. That would be a welcome outcome for students and industry.
