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Changes in Part 147 to Bolster Maintenance Workforce

Recent changes to the oversight structure of 14 CFR Part 147 aviation maintenance technical schools (AMTS) stand to offer several benefits to business aviation, including greater access to aircraft and powerplant (A&P) technician jobs and added flexibility to address modern aviation training needs.

In 2015, the FAA published a notice of proposed rulemaking (NPRM) titled “Aviation Maintenance Technician Schools” that sought to amend regulations governing oversight of these schools for the first time since 1992.

That NPRM drew numerous public comments encouraging the FAA to consider allowing competency-based training in lieu of rigid minimum timeframes, and to permit the use of satellite training locations. The FAA subsequently published a supplemental NPRM in 2019 expanding a previously proposed rule to allow aviation maintenance technician schools to use competency-based training and satellite training locations.

Pushing for Community Input

In addition to its comments on the NPRM, the Aviation Technician Education Council (ATEC) petitioned Congress for a mandate directing the FAA to remove and replace Part 147 with community-drafted language. That language was later included in Section 135 of the Consolidated Appropriations Act of 2021, and FAA Acting Administrator Billy Nolen signed an interim final rule promulgating the new Part 147 in May 2022. The new regulation took effect on Sept. 21, 2022.

“These improvements will help us educate the future workforce and meet the demands of the evolving aviation community,” the FAA stated. “Under the new rule, technical schools will update curriculum and incorporate technical training that aligns with the current industry standards.”

Shifting Administrative Oversight

The change also allows AMTS to implement training curricula without FAA approval, although the agency will maintain its testing authority and continue to oversee a school’s equipment and faculty. Administrative oversight of accredited schools – for grading systems, record keeping practices, absentee policies and other measures – now shifts from the FAA to the U.S. Department of Education.

“NBAA has advocated for years for updated training standards to better match the needs of today’s aviation environment,” said Stewart D’Leon, CAM, NBAA director for environmental and technical operations. “These are very positive changes that allow AMTS to advance students through training as they demonstrate their knowledge and skills, without certain time limitations.”

“This ruling gives schools a lot of flexibility. They don't have to ask the FAA for permission on how they teach, but instead, they are responsible for meeting the end goal, which is to produce a person with the skills and knowledge necessary to be certificated.”

Crystal Maguire Executive Director, ATEC

A Performance-Based Mindset

Charles Horning, associate professor with the Aviation Maintenance Science Department, College of Aviation at Embry-Riddle Aeronautical University, noted the change aligns Part 147 schools with the shift to competency- and performance-based training methodologies, as seen with the Airman Certification Standards (ACS) for flight training released in 2016.

“These changes gives AMTS greater ability to create curriculum that can be implemented faster, because the curriculum no longer requires FAA approval,” Horning said. “The school may create whatever curriculum they feel best prepares their students for FAA testing.”

“This ruling gives schools a lot of flexibility,” agreed ATEC Executive Director Crystal Maguire. “They don’t have to ask the FAA for permission on how they teach, but instead, they are responsible for meeting the end goal, which is to produce a person with the skills and knowledge necessary to be certificated.”

More Sim Tech Training Expected

As one example, Horning cited greater use of simulation technology in aircraft maintenance training that gives students a virtual, inside look into aircraft powerplants and other systems, offering far greater detail than paper schematics.

“Under the new rule, we do not need to submit that simulator-based curriculum to the FAA for their approval,” he continued. “The agency will continue to monitor how well our graduates perform, but as graduating students still pass the FAA test, how [the school] gets them to that point is up to the school and its accreditation body.”

That approach should also help drive new candidates for A&P jobs, D’Leon added. “This new guidance will help maintenance schools train the next generation of aviation maintenance professionals in a way that better prepares them to walk straight from graduation into the workforce,” he noted.

“This new guidance will help maintenance schools train the next generation of aviation maintenance professionals in a way that better prepares them to walk straight from graduation into the workforce.”

Stewart D'Leon CAM, NBAA Director, Environmental & Technical Operations

“Employers now have greater opportunity to work with AMTS to develop training programs that meet their needs,” Maguire said. “In the past, schools had curriculum mandates and seat time requirements that offered no ‘wiggle room.’ Now, both sides can work together in partnership with much greater flexibility.”

That includes more chances for A&P students to learn skills away from the classroom. “On-site learning at an actual, certificated repair station or air operator may be the biggest opportunity enabled by these changes,” she said. “It really helps close the gap between classroom education and real-world training.”

Adapting to a Changing Industry

In addition to potential benefits to the aviation workforce, Horning hopes the new guidance for Part 147 schools will also help streamline the industry’s ability to adapt to evolving requirements, including FAA testing parameters that reflect these changes.

“The ACS system is designed to be fluid, and reviewed periodically so that codes related to old and outdated topics can be taken out and new codes added that cover more current topics.”

Charles Horning College of Aviation at Embry-Riddle Aeronautical University

“[Flight training] was kind of in a rut for many, many years, teaching and testing on the same material that didn’t change with the industry,” he said. “The ACS system is designed to be fluid, and reviewed periodically so that codes related to old and outdated topics can be taken out and new codes added that cover more current topics.”

“We now have a better regulatory framework to build pipelines between local high schools and A&P schools,” she continued. “AMTS can create curriculum that begins in high school, allowing those students to move straight into maintenance schools or even directly into maintenance internships.”

To further that process, Maguire encouraged those working in business aviation to explore these options to help develop new talent. “Our focus must be on reaching out in our communities to build these talent pipelines,” she concluded. “We obviously face a talent shortage, and this is how we can get more people engaged with the aerospace industry.”

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