ATEC Provides FAA Recommendations for AMTS additional fixed locations to support dual enrollment

After conducting an FAA-requested survey to support the part 147 rulemaking, ATEC provided additional comment on how the agency may facilitate additional fixed locations for certificated aviation maintenance technician schools. 

AMTS are facing unprecedented demand for A&P graduates, to meet the growing need schools are looking at innovative ways to increase enrollment. Dual enrollment programs, whereby AMTS provide course instruction at local high schools, allowing students to earn credit towards an A&P program, are growing in popularity as a solution to the problem.

​While the current regulation does not prohibit AMTS from providing courses at another location, local inspector opinion on programs allowable under the regulation varies considerably, with some expressly forbidding the practice. Local office personnel that prohibit dual enrollment generally cite language in FAA Advisory Circular 147-3B, which states that an AMTS “may not operate as a satellite facility” and that “all AMTS must be FAA-certificated as separate facilities.”

Notwithstanding the fact that an AC cannot impose requirements or prohibitions, ATEC beseeched the agency to carefully consider any regulatory language (i.e., satellites vs. fixed locations) that might create confusion in enforcement. It also suggested that the agency utilize current OpSpecs standard templates to introduce additional fixed locations—OpSpecs paragraph A101—and course work provided at those locations—OpSpecs paragraph D100. Keeping in line with standard practice for other air agencies that hold OpSpecs (as opposed to training specifications), the additional locations would be under the control of the AMTS primary location and subject to FAA oversight.