Pandemic conditions may accelerate Part 147 reforms.
Well before COVID became a household word, the aviation industry was already struggling with meeting the demand for qualified aviation maintenance technicians (AMT). For years, the number of applicants for AMT training has been outstripped by the number of experienced AMT leaving the field, leading to forecasts of crippling labor shortages. Another hurdle to building a sustainable pipeline of AMT talent, according to industry observers, is the antiquated Part 147 regulations that limit the flexibility of AMT schools and their ability to deliver graduates trained for the modern aviation workplace.
Originally established under the US Civil Aviation Administration, a precursor to the FAA, 14 CFR Part 147 governs all aspects of training toward an airframe and power plant (A&P) certificate. AMT schools must teach a prescribed number of hours on general, airframe, and power plant topics; 1,900 of those hours are required to be “class-seat hours,” where students must be physically present. Graduates must pass the FAA written and oral tests, based on the agency’s mechanic Airman Certification Standards (ACS), to receive their A&P certificates. Neither the regulation nor the subject areas it dictates be taught have been significantly revised since 1962.
Under Part 147, AMT schools aren’t only told what curriculum to teach, they’re told exactly how that curriculum must be taught, and they must obtain FAA approval to modify operating procedures. For example, each AMT student must still learn wood and fabric repair techniques suitable for antique aircraft, while their schools face a daunting regulatory gauntlet to receive approval for teaching avionics and health and usage monitoring systems.
Proponents of reform argue that the FAA’s antiquated mandates for AMT education inhibit those schools’ flexibility to operate in an accredited education environment; accredited institutions are generally given flexibility on curriculum and how that curriculum is delivered. Industry observers also charge that the 58-year-old Part 147 curriculum contains large gaps, such as helicopter-specific systems and maintenance, that leave students ill prepared for work in modern aviation. They urge the adoption of Part 147 reforms that would allow schools flexibility in how they deliver the curriculum required by the ACS while fully preparing students to meet industry needs.
Industry advocates, led by the Aviation Technician Education Council (ATEC), a group that represents US AMT schools, have been working with the FAA for more than a decade to modernize Part 147. Unfortunately, the drawn-out process has led to FAA-proposed rules that further limit flexibility. In response, the industry has employed a different strategy for change: to force reform through congressional mandate.
In December 2019, the Promoting Aviation Regulations for Technical Training (PARTT) 147 Act was introduced in Congress (S. 3043 / H.R. 5427). The industry-supported, bipartisan, bicameral bill, if passed, would direct the FAA to use community-drafted, performance-based regulations to define the A&P curriculum and to defer to the Department of Education in areas concerning the quality of education. The FAA would maintain oversight of an AMT program’s facilities, equipment, and instructor qualifications. The FAA would still control the ACS, which in turn drive AMT education curriculum, providing the agency with the means to evaluate the performance of individual students, as well as the performance of the AMT school, through analysis of student passage rates.
The overall result of the law would be the modernization of how aviation technical schools teach, which includes the flexibility to adequately support the aviation industry’s technical workforce needs.
Along Comes COVID
In the spring of 2020, as the PARTT 147 Act was gaining momentum in the US House and Senate, COVID struck. Overnight, AMT schools across the country closed. Administrators and faculty began assessing how to respond to the virus. Educators of all types across the country have demonstrated the pitfalls of pivoting to an online learning platform; this was exceptionally difficult for AMT schools, given the FAA approvals required to deliver any of the mandated 1,900 class-seat hours virtually.
By the end of March, the FAA announced a “short-circuit” relief program that allowed AMT schools greater flexibility to use electronic and online training and assignment delivery during the pandemic. Many schools took advantage of this offer.
In May, ATEC surveyed its member schools about the impact of COVID on their operations. The group asked the same questions again in September to gauge the level of change across the aviation maintenance training industry. In May, two schools announced they’d suspended operations. This number increased to five in September. Conversely, the number of schools moving to some level of online instruction steadily increased as the pandemic dragged on.
“In the United States, we have about 180 certificated programs, with a little under half of them responding to the survey,” says ATEC Executive Director Crystal Maguire. “All of these schools were traditionally hands-on, with only four having received permission for any online content prior to COVID. By this summer, about 60% of our schools had some content online.
“Interestingly, the majority of the schools would like to maintain the level of virtual instruction beyond the pandemic time line,” says Maguire. “This is a piece of the flexibility we seek.”
Unfortunately for some, the flexibility wasn’t enough in the face of the current Part 147 regulations. ATEC estimates that 20% of the country’s AMT schools have suspended their programs, either temporarily or permanently, since March.
Requirements Form Barriers
North Idaho College began the long process of AMT certification in 2013, receiving its airframe program certification in 2015.
“We planned to eventually have a full airframe and power plant program,” says North Idaho College Aerospace Director Patrick O’Halloran. “We’d received a federal grant to add aerospace to the college as a part of solving manufacturing needs and started with the airframe side. We were certified in 2015 and, as I like to say, we became the newest antiquated aircraft maintenance school due to the old Part 147 rules.”
Adding the power plant certification was more expensive and required additional work. In 2018, the school began drafting its power plant curriculum for certification. Then, the FAA released a supplemental NPRM with more suggested changes to Part 147. That, paired with the industry’s later action on the PARTT 147 Act, muddied the waters.
“We were in the middle of deciding if we would continue efforts to pursue the power plant program or wait for the new rule when COVID hit,” O’Halloran says. “Our lease would be up for our building in June 2021, and we were considering our options based on pushing forward—renew or get a larger building. Sadly, 2020 proved to be the wrong year to make that decision. Financially, we chose not to continue our lease and announced we’d be closing the program.
“The hardest thing about this final decision is we had the highest number of credible applicants this year,” O’Halloran continues. “People want to become aircraft mechanics.”
North Idaho College will continue its aviation maintenance operations through the end of the 2020–21 school year, ensuring that current students can complete their training. Taking advantage of the FAA relief program, the school was able to offer some lectures online until Idaho moved to Stage 4 of its reopening plan, allowing classroom attendance again.
“The current Part 147 program played a big part in our decision [to close],” O’Halloran says. “AMT [education] is really complicated in terms of record keeping and detail. It requires more-involved manpower than any of our other programs. For a bigger school, that can be absorbed, but it’s not as easily done for a small, rural school.”
Moving to Performance-Based Standards
At Southern Utah University (SUU), the stakes couldn’t have been higher. The school had just been certified to present the first aviation maintenance curriculum in the United States focused on helicopters, beginning with classes in January 2020.
Luckily, due to their recent work with the FAA in gaining approvals for the maintenance training program, the school administration had a strong relationship with their local FAA Flight Standards District Office and were able to receive approvals for virtual learning when the pandemic hit in the spring.
SUU began building the program in 2016, meeting the antiquated requirements of Part 147 while working with the FAA to build in a number of rotor-specific aspects to the curriculum. “We still have to teach the airplane curriculum, but we built it so we are teaching the basics on airplanes, then going over and above to teach additional information on helicopters,” says Jared Britt, director of global aviation maintenance training for SUU.
“For instance, the regulations state that students must learn about flight controls. We teach the basics on airplanes and the majority of that curriculum on helicopter flight controls. That said, these were workarounds,” Britt says. “The regulation needs to change significantly for schools to provide the highest level of training to meet today’s industry needs.”
Britt chairs ATEC’s Legislative Committee and is a strong supporter of the PARTT 147 Act. He believes the legislation will create a regulation that allows the industry the flexibility to meet workforce needs creatively and to embrace new ways of increasing the ranks of US aviation mechanics.
“We’re training students to meet the airman certification standards, the ACS, which is a living, working document that governs curriculum and testing,” Britt says. “Yet at the same time, Part 147 details everything we’re supposed to teach and how we’re to teach it. Some of those skills are antiquated, while other skills aren’t required but are very much needed in today’s marketplace.”
Britt argues for developing a performance-based approach to AMT education. “Our argument is to let us build curriculum that adheres to the ACS and that highlights the skills and knowledge an applicant for certification must have. As they update the ACS, we update our training. Let the school’s pass rate dictate the success in teaching.”
The new rule would focus on what to teach and remove the rigid controls on how the schools teach the material. This would permit more creativity and flexibility in how the curriculum is presented. It also would allow industry participation.
“[The PARTT 147 Act] opens the door for partnerships with industry companies and groups to come in and donate equipment and information to help students graduate with better skills and knowledge to work on this technology,” Britt says. “Schools [can] work with local companies to expand training. In the end, it’s a reduction in cost because new A&Ps don’t have to then go get more training in current technology that wasn’t covered in Part 147 training.”
Britt argues that this increased flexibility would also help AMT schools weather storms such as economic downturns and COVID by removing barriers to quickly changing curriculum to meet demand. “The rules as they stand are a barrier due to the red tape that must be navigated in ‘normal’ times,” says Britt. “With the pandemic and the flexibility schools need to continue instruction, the rules become almost insurmountable obstacles.
“If I want to change any aspect of my curriculum, including how I deliver it, I need to get FAA approval for that change,” Britt says. “If I needed to move all instruction online to keep students moving, for instance, I’d have to go to the inspector and have that inspector approve it. That’s not getting it done efficiently.
“There was no flexibility for schools to change prior to the COVID-19 waiver,” Britt continues. “That’s one of the reasons why 20% of schools had to at least temporarily stop operating their AMT programs.”
A Silver Lining?
While COVID has driven some schools out of business, the widespread disruption the pandemic has brought to every aspect of life means it has also created conditions favorable to change. Schools that were already looking at ways to offer more flexible learning opportunities as a cost-saving measure are in a strong position today, as are those pivoting quickly to take advantage of moving online.
For one school in particular, the FAA waiver was just the break it needed to become one of the few full-hybrid model AMT schools.
Wichita State University Tech (WSU Tech) in Kansas had already started the process of providing online learning prior to COVID. The curriculum had already been loaded into the school’s online learning tool, and the faculty had already created most of the program’s Level 1 labs. Additionally, WSU Tech students are required to have laptops, making a sudden transition to online learning, such as happened this past spring, easier.
“We got our COVID operations manual approved by the FAA three days after the school announced an all-online environment,” says Jim Hall, WSU Tech dean of aviation and manufacturing, National Center for Aviation Training. “We did synchronous online learning throughout the spring, then came back to complete Level 3 labs in June.”
During the transition, the faculty was able to complete a hybrid operations manual, which was approved in June. Now the program can offer three hours of online material every day, requiring students to be in class only four hours a day. Previously, the school offered two cohorts, one during the day and one in the evening. The new hybrid system frees enough classroom space to add a third four-hour shift of students.
In the short term, the third shift allows WSU Tech to offer more socially distanced options while still significantly increasing enrollment. Already, enrollment is up 50 students, or 30% per trimester, and the school has hired three new instructors.
“Upward to 60% of schools want to move to this model,” Hall says. “I’d been working with our PMI [primary maintenance inspector] at the FAA for quite some time trying to go to a hybrid model and had encountered a great deal of resistance up until COVID. Part 147 is such a mess.
“If COVID hadn’t happened, I fully believe I’d still be battling to get this off the ground,” Hall says. “Now, thanks to the COVID-induced deviation, we’re in a better position to implement new changes once a new 147 is released.”
The Future of Part 147
As the industry awaits the movement of the PARTT 147 Act through Congress and potential further action from the FAA, members of the rotorcraft community can still add their voices to the conversation.
ATEC’s website hosts a page dedicated to the subject of Part 147 reform, supplying information and advice on how to support the PARTT 147 Act’s movement through Congress. You’ll find additional information on both the FAA’s proposed rule and the PARTT 147 Act, along with ways to urge your representative and senators to support the bill.
Another way to drive desired changes in AMT education, suggests ATEC’s Maguire, is through revisions to the ACS, the FAA’s standards that drive AMT education. An FAA–industry working group is currently working to update a number of different airman certifications, including those for A&Ps.
Changes to the ACS will directly drive more helicopter-specific curriculum in the FAA knowledge tests and therefore in the technical training needed to meet those standards, says Maguire. While the FAA doesn’t publish a rolling draft of the ACS, the public can review it on the ATEC website and submit comments to AFS630comments@faa.gov.
Part 147 Overhaul: 4,332 Days* and Counting ….
*As of Nov. 17, 2020
Jan. 8, 2009
An industry working group formally recommends broad changes to 14 CFR Part 147.
Nov. 19, 2015
The FAA issues a notice of proposed rulemaking (NPRM) with sweeping changes to AMT education. However, the industry objects to many changes that limit flexibility in teaching, recommending instead that the Department of Education oversee how education is delivered and the FAA focus on learning outcomes, testing, candidate certification, facility equipment, instructor qualifications, and material requirements.
Oct. 5, 2018
The FAA Reauthorization Act of 2018 is signed into law, mandating that the FAA release a new Part 147 by Apr. 5, 2019.
Apr. 16, 2019
Eleven days after the congressionally mandated deadline, the FAA issues a supplemental notice of proposed rulemaking (SNPRM) for Part 147. The industry continues to object to yet another layer of requirements and approvals that schools must meet and obtain before implementing competency-based programs and providing content away from their primary locations. Together with the NPRM, this SNPRM doubles the length of the original Part 147. Again, the industry argues for the development of a modernized framework to meet workforce development needs, including the flexibility to develop pipeline programs with high schools and employers.
Dec. 12, 2019
Congress introduces bicameral, bipartisan legislation, the Promoting Aviation Regulations for Technical Training (PARTT) 147 Act (S. 3043 / H.R. 5427), directing the FAA to replace current training requirements with new, community-drafted regulation. The legislation is introduced with broad industry support.