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.