After nearly a decade, the FAA’s rule governing aviation maintenance schools is nearly ready for prime time. Robert Moorman explains.
The long-awaited update to the part 147 rule governing aviation maintenance technician schools could become final by the first quarter of 2017, which is good news for the industry, academia and prospective aircraft maintenance technicians (AMTs). But the way the rule was developed and refined could be the bigger story and serve as a template for future rulemaking, according to numerous people interviewed for this article, including members of the Aviation Rulemaking Advisory Committee (ARAC) formed years ago to recommend changes to part 147.
Absent from this Notice for Proposed Rulemaking (NPRM) process was the rancor and inflexibility that led to the H.R. 5900 final rule strengthening training requirements for airline-bound first officers. That rule also required a base 1,500-hours of flight time for pilots to be hired by part 121 operations.
For revising part 147, progressive thinking appears to be replacing the method of FAA dominating how the final rule would look. In addition, the industry - AMT schools and various air transportation interests in this instance - are not being viewed by critics as mindless adherents to the bottom line and deaf to safety concerns.
“We were polar opposites from the pilot rule from a regulatory standpoint,” said Ryan Goertzen, ARAC and working group member and current Chief Aviation and Academic Officer, Spartan College of Aeronautics. “Yes it took too long. But I am pleased with the progress that has been made.”
Goertzen, president of the Aviation Technician Education Council (ATEC) said this NPRM “changed the landscape where industry, schools and FAA worked together.”
The proposed rule updating part 147 moves toward a competency-based standard for AMT instruction rather than the inflexible clock time standard in the current rule. But it is not a complete transformation.
“The proposal is better than the existing rule, yet there are some things we could do in the final rule to make it better,” said Crystal Maguire, Business Manager for ATEC, which represents aviation maintenance technician schools.
ATEC, in collaboration with 13 other interested parties, underscored their concerns in comments earlier this year to FAA’s NPRM updating part 147: “Put simply, the proposal would impose 20th century educational practices on a 21st century industry ... A competency-based standard, free of defined schedules and specific hour requirements, will allow industry to transition away from seat time [exclusively] in favor of a structure that creates flexibility...”
The overall goal is to prepare AMTs to be hired anywhere, by any company needing a qualified aircraft mechanic. “Under the current structure, we’ve never been able to produce an A&P that can walk out of a school and dive into a job without supervision, anywhere in the industry,” said Raymond Thompson, Associate Dean, College of Aviation, Western Michigan University, who served on the ARAC and subsequent working group. “I don’t see that changing unless we go to something that is more like an EASA (European Aviation Safety Agency) model.”
Past moves to create an EASA-like maintenance rule in the US were unsuccessful. Consider the “Part 66 debacle,” Thompson recalled. Many years ago, the FAA tried to float a Part 66 AMT-T (transport) category, where AMT graduates would specialize on a particular aircraft or engine. That effort failed miserably, but this proposed rule updating part 147 is far better that what is offered currently, several ARAC members told CAT.
One of the bigger changes in the proposed rule is how schools evaluate students. The 1,900-hour minimum threshold in the present rule still applies in the NPRM. But unlike pilot training, which specifies how much time should be spent teaching, this proposed rule states that schools offer a curriculum that achieves 1,900 total hours. It is up to the school to determine how to breakdown the curriculum and by what methodology.
Under the proposed rule schools may be certificated by clock hour or credit hours. But “seat time” (time in the classroom) could still be dictated in a credit hour system. Schools falling under the credit hour methodology would still have to demonstrate to the FAA that its total credit hours would be equivalent to clock hours.
The working group used a conversion process to go from clock hours to credit hours, but here is a rough rule of thumb: 37 ½ clock hours is equivalent to one credit hour, although there is more to the formula, said Chuck Horning (Ph.D.), Department Chairman, Aviation Maintenance Science, Embry-Riddle Aeronautical University, and member of the ARAC and subsequent working group revising part 147.
Credit hours are based on the Carnegie Credit Hour formula, which defines a credit hour as the unit of measuring educational credit, based on the number of classroom hours per week throughout a term. Carnegie defines a semester unit of credit as equal to a minimum of three hours of work per week for a semester minimum of 16 weeks. Typically, this would be one-hour lecture plus two hours of homework or three hours of lab for 16 weeks. In certain circumstances, it is possible to have more hours of instruction, but not less, according to one definition of the formula.
Under the present rule, if a student misses instruction time, he/she would have to make up the time and material missed. Students would not have to make up the clock time under the proposed rule.
It was suggested during the first ARAC meeting in 2007 that the clock time component be excised from the NPRM. That proposal didn’t fly because of concerns that removing the time component would dilute training.
Those charged with updating part 147 recommended bumping general instruction by 50 hours to 450 hours, adding 50 hours of airframe instruction to 800 hours and dropping 100 hours of the Powerplant requirement to 650 hours.
The change in hours was recommended because most of the technology advances are in airframe materials, such as composites and digital control devices. The NPRM crafters felt that more general instruction was needed in soft skills such as human factors, safety management and electronic theory.
Another change in the proposed rule involves the curriculum. The specific curriculum requirement is taken out of the new rule, while the subject headers remain. Specific courses required would be published as an advisory circular initially and then become part of an operations specification document schools would follow. With this pathway created, AMT education could evolve without the need for a formal, time-consuming rulemaking process. Proposed changes to the curriculum could be reviewed first by a maintenance training review board before becoming part of the operations specifications document. The new approach to the curriculum outlined in the proposed rulemaking helps in other ways by creating a mechanism whereby “industry can be more involved with academics,” Goertzen said, “because they will have the ability to help set the curriculum for the future.”
The FAA’s rule revising part 147 is praised for its homogenous, forward-looking approach to rulemaking, but even its proponents don’t accept the decade it has taken to get to this point. Knowing the history of revising the rule, however, puts the delay into perspective. The ARAC to revise part 147 was formed in July 2007. The Committee was given a one-year mandate to complete the proposed rule; it received an extension to 2008 to finish the task. But the February 12, 2009 fatal crash of Colgan Air Flight 3407 near Buffalo, N.Y. suspended for years all work on the new rule. The highly publicized crash of the Bombardier Dash 8-400, which claimed the lives of 49-passengers and crew, monopolized the FAA’s time to coming up with tougher training standards for professional pilots.
Finally, in early 2011, Stephen Douglas, then FAA Division Manager, Aircraft Maintenance Division helped resurrect updating part 147 by forming a working group of former ARAC members. The group found that six of the initial recommendations reported to the FAA didn’t require rulemaking, including distance education and guidance for inspectors of maintenance training schools. Work on revising part 147 continued. In early 2016, the comment period on the NPRM ended. Members of the working group and industry experts expect the final rule to be out by the end of 2016 or first quarter of 2017.
If the revised rule comes out as proposed, every school with an AMT module would be affected. “The biggest impact will be a rewrite of the [AMT] curriculum,” ERAU’s Horning said. “That is due to the added subject material and the redistribution of the powerplant hours.”
Yet no school CAT interviewed seemed particularly concerned about the revisions in part 147. “If the rule comes out as proposed, I don’t see a major upheaval in my program,” at Western Michigan University, Thompson said.
Updating part 147 will allow schools maintenance training programs to “tailor their curriculum and still hang on to certain core requirements,” added Andrew Smith, Associate Professor for the part 147 program at Kansas State University.
Unique, perhaps, is that this rule is easier to stomach.
“To be able to go to an Ops Specs environment caters to our strengths,” in composites and turbine technology and other areas, said Mark Thom, Associate Professor, Aeronautical Engineering Technology, Purdue University. Purdue’s AMT/A&P module is part of its four-year undergraduate engineering program.
Thom offered a cautionary note on the rewrite. “Now that we have a decent rule, it has to be translated in a way that the local FAA knows how to oversee it,” Thom said. “That is going to be the real challenge.”
Most interviewed believe that the final rule will be very close to the NPRM, with some minor tweaking. The FAA is not allowed to comment on pending rules, “but I would be shocked if many of the proposals in the NPRM were not adapted into law,” Goertzen said.
Irrespective of the pending rule, higher education for AMTs is becoming a factor. ERAU offers two-year Associate and four-year Bachelor degrees for AMTs. Most on the AMT track vie for the four-year plan, Horning said, because they eventually want to be management and employers are looking for candidates with at least two years of college. CAT heard similar accounts at other universities.
On Their Own
Maintenance, Repair and Overhaul (MRO) operations said they welcome the long-awaited revision to part 147. Yet some MROs have taken the initiative to ensure that AMTs are better qualified before they’re hired.
Greensboro, North Carolina-based HAECO Americas is working to establish a number of four-year pre-AMT programs at various high schools in the region that would provide tours of aviation facilities, job shadowing opportunities and paid internships.
Kip Blakely, vice president of government and industry relations for HAECO Americas explained the proactive move: “We weren’t pleased with the graduates we were getting from the community college [Guilford Technical Community College, Jamestown, N.C.],” he said. “We’d grown accustomed to the fact that when someone with an A&P certificate came to us, it meant they had the license. But it would take two years before they could be productive in one of our facilities.”
Blakely said it was the MRO’s fault for not being more proactive. HAECO Americas stronger relationships with high schools better equips students with basic MRO knowledge before going to a school with an AMT program. The goal, Blakely said, is to narrow the productivity gap from two years to months.
HAECO Americas is looking to fill numerous positions, but is having difficulties in hiring technicians and engineers. Parent company HAECO, based in Hong Kong, has its own AMT schools where students live on campus and operate under a different regulatory system. “But they too are experiencing the same problems of not having enough qualified AMTs,” Blakely said.
AMTs come to MROs with various levels of experience. There is the high school graduate with an AMT license from a technician school; an AMT graduate from a two-year or four- year program at a college or university; and an experienced AMT from the military, who is transitioning to the civil sector.
Newly minted AMTs present the biggest challenge to MROs and other employers. In an attempt to obtain better AMTs with little or no experience, AAR partnered its MRO facilities with A&P/AMT schools. “The idea is to seed our requirements into the curriculum, whether it is regulatory-driven or not,” said C. Rayner Hutchinson III, Vice President Quality and Safety, AAR Corp., a large MRO and parts company.
During the early part of their AMT study, “we would like to bring students into apprenticeship programs,” said Hutchinson. “So when they graduate, they actually have work experience in an AAR MRO.”
This self-help approach to getting better AMTs is not an indictment against the soon-to-be released final rule updating part 147. On the contrary, said the MRO executive. “I think this new rule is a huge step forward” and those people responsible for the rewrite “have taken the technician training regulations out of the dark ages and brought them in line with where technology is today.”