The Road to Reform
THE ISSUE
Title 14 Code of Federal Regulations (CFR) part 147 governs aviation maintenance technician schools that hold a Federal Aviation Administration (FAA) certificate (see also the ATEC school map, and filter by "Airframe and/or Powerplant certificate"). The regulation was originally established under the Civil Aviation Administration and re-codified into 14 CFR in 1962. Since that time, neither the regulation, nor the subject areas it dictates be taught, have significantly changed. During the same time, the design regulations mandating the standards to which a civil aviation article must be certificated and maintained have changed innumerable times. These changes have enhanced safety significantly; they also mandate more sophistication and knowledge in maintenance personnel.
The need for regulatory reform is not debated. A 2003 Government Accountability Report (GAO) report called for updates to curriculum requirements, recognizing that certificated programs do "not fully prepare A&P mechanics to work on commonly flown, technologically advanced commercial aircraft,” and that “today’s modern aircraft require A&P mechanics to have a different set of skills than those being taught at aviation maintenance technician schools.” An Aviation Rulemaking Advisory Committee, made up of industry and FAA representatives, issued a December 2008 report with specific recommendations to update static minimum curriculum requirements dictated in part 147.
“today’s modern aircraft require A&P mechanics to have a different set of skills than those being taught at aviation maintenance technician schools.”
Since then, ATEC has been at the forefront of the demand for change. In November 2015, the FAA issued a part 147 notice of proposed rulemaking. ATEC submitted extensive comments, calling for a less-prescriptive rule that would allow for competency-based programs and the freedom to cater training to industry needs. ATEC’s position was supported by 14 aviation organizations, discouraging the NPRM’s continued reliance on class time at the expense of technical capability. To continue the momentum, ATEC representatives held face-to-face meetings, submitted supplemental comments and garnered legislative support for a rule that would provide better trained personnel to meet industry workforce needs.
During roughly the same period of time, an FAA-industry working group undertook a massive effort to improve mechanic certification testing. The Mechanic Airman Certification Standards (ACS) will replace current practical test standards (PTS), and clearly define minimum knowledge and skill requirements for A&P mechanics. Once completed, the ACS will provide the framework for the written, oral and practical mechanic tests; and subsequently, a guide for revising handbooks, oral questions, practical projects and the knowledge test bank. That means outdated questions and projects will be replaced with relevant assessment material, and incorrect, incomplete or inadequate questions and projects will be updated or removed.
Given new testing standards and the timing of a new part 147, the ACS working group made a formal recommendation that the FAA:
- Revise part 65 to provide the baseline standard for mechanic knowledge and skill requirements
- Remove any reference to curriculum requirements or subject areas from part 147
- Reference the ACS in AMTS operations specifications to ensure that training and testing are directly correlated
- Utilize the ARAC Airman Certification System Working Group as the driver for changes to training requirements
In September 2017, the FAA announced its intention to issue a Supplemental Notice of Proposed Rulemaking (SNPRM). The SNPRM was published on April 16, 2019, proposing additional provisions to address competency-based training and satellite locations. While the community applauds the agency for offering a solution, elements in its proposal miss the mark. The SNPRM layers in a complicated web of requirements and approvals for competency-based programs and satellite locations, many of which duplicate accreditation mandates.
In its comments to the SNPRM, the council reiterated its plea for FAA deference in all matters concerning the quality of education, an element that falls squarely in the Dept. of Education's purview. It asked the agency to focus its oversight on items specific to a certificated A&P program, such as facility, equipment, and material requirements, unique instructor qualifications, and assessment based on student performance of the mechanic test.
It is ATEC's position that accredited higher institutions of learning not be subject to duplicative--and sometimes contradictory--government requirements. The Dept. of Ed and its accrediting bodies are the education experts, and work in partnership with our schools to ensure educational outcomes are achieved. The council's comments to the SNPRM offered alternative language that gives our schools more flexibility, and puts less burden on our stewards of aviation safety. (See the ATEC Policy Brief for a summary of the council's objections to the rulemaking.)
The education community awaited a final rule from the FAA for nearly two decades. Tired of the wait and wary of the inflexibilities a new rule would introduce given previous FAA proposals, the council engaged its elected leaders to ensure the final rule provides the flexibility industry needs to train the next generations of aviation technicians.
To that end, on Dec. 12, 2019, the U.S. Congress introduced the Promoting Aviation Regulations for Technical Training (PARTT) 147 Act, legislation that would require FAA promulgation of community-draft language to replace the current part 147. ATEC called on the community to urge elected leaders to sign on in support of the bill, and in late 2020, the call was heard.
On Dec. 27, 2020, Congress passed the Consolidated Appropriations Act (H.R.133/Public Law 116-260). In section 135 of the massive bill, Congress directed the FAA to remove and replace the current part 147 with community-drafted language. Under the law, the FAA is required to promulgate the new rule by March 27, 2021.
The interim final rule was published on May 24, 2022, with a Sept. 21, 2022 effective date.
For more information on the new rule and resources to aid implementation, visit The New Part 147.
TIMELINE AND RESOURCES
For the latest Part 147 news, click here!
2023
June 12, 2023: FAA publishes final rule, effective June 13, 2023
2022
May 24, 2022: FAA publishes interim final rule, effective Sept. 21, 2022
2021
Dec. 28, 2021: FAA Administrator Dickson responded to a congressional query on the status of the interim final rule, which by law was supposed to publish in March 2021. In his response, Administrator Dickson stated that the agency was "committed to completing this rulemaking as expeditiously as possible," and that the interim final rule was expected to publish this May.
Sept. 1, 2021: Lawmakers pen a letter to FAA and DOT leadership, calling for swift implementation of the part 147 congressional directive.
March 2021: The Department of Transportation's semi-annual regulatory agenda is published to include the final interim part 147 scheduled for publication in November 2021.
Jan. 13, 2021: ATEC holds webinar giving an overview of the new rule and introducing resources to aid implementation.
2020
Dec. 27, 2020: Congress passed the Consolidated Appropriations Act (H.R.133/Public Law 116-260), to include the part 147 direct rule.
Dec. 21, 2020: The Aviation Safety Bill, to include the PARTT 147 Act, is rolled into the massive "CoronaBus" legislation, and scheduled for House vote.
Dec. 14, 2020: House and Senate transportation committees come to agreement on an Aviation Safety Bill that includes the part 147 direct rule.
Dec. 7, 2020: An aviation industry coalition, including 23 organizations, pen letter to House Transportation & Infrastructure Committee leadership asking members to retain Senate language regarding part 147 in a final aviation certification bill.
Nov. 18, 2020: ATEC holds webinar, Part 147: Where Are We Now, to inform the community on the latest advocacy efforts and how schools can prepare. (Tune in to the recorded version.)
Nov. 18, 2020: The PARTT 147 Act advances through Senate Commerce Committee markup; the Act is made part of the bipartisan Aircraft Safety and Certification Reform Act of 2020 (S. 3969).
Sept. 15, 2020: Washington state-based schools and organizations penned a letter to their elected leaders, who also hold key positions on committees with jurisdiction over aviation issues, to consider the PARTT 147 Act in committee mark-up.
Aug. 10, 2020: ATEC voices formal call to action and initiates massive grassroots effort to garner additional congressional support for the PARTT 147 Act. Releases informational video and legislative toolkit.
May 7, 2020: ATEC publishes a policy brief to help educate congressional leaders on the issue and the council's objections to FAA proposals.
2019
Dec. 13, 2019: ATEC initiates grassroots campaign to garner legislative support of the PARTT 147 Act.
Dec. 12, 2019: Congress introduces bicameral, bipartisan legislation, The Promoting Aviation Regulations for Technical Training (PARTT) 147 Act (S.3043/H.R.5427), that would direct the Federal Aviation Administration (FAA) to replace current training requirements with a new, community-drafted regulation. The legislation is introduced with broad industry support.
June 17, 2019: Industry coalition files comments in support of ATEC position, calls for outcomes-based, simplified approach, and deference to Department of Education accreditation requirements.
June 12, 2019: ATEC submits comments to the supplemental notice of proposed rulemaking, ahead of the June 17 deadline.
May 30, 2019: The council holds an online webinar to brief the community on the proposal and to prepare institutions to submit comment.
May 1, 2019: Overview of the supplemental notice of proposed rulemaking published in Aviation Week's InsideMRO, Proposed Regulation Raises Questions About FAA’s Role In Education
April 16, 2019: The FAA published a supplemental notice of proposed rulemaking for part 147.
2018
Oct. 5, 2018: The FAA Reauthorization Act of 2018 is signed into law. Provision mandates FAA promulgation of part 147 by April 5, 2019.
May 7, 2018: Senators introduce bill that would mandate promulgation of part 147.
April 24, 2018: ATEC comments on Southern Utah University petition for exemption from part 147.
March 12, 2018: ACS working group reiterates the need to ensure testing standards (the AMT ACS) and training standards (dictated through a new part 147) are correlated.
2017
Sept. 15, 2017: Sen. Hatch (UT) requests update on status of supplemental rulemaking.
Sept. 4, 2017: FAA announces it will issue a supplemental notice of proposed rulemaking.
Aug. 22, 2017: Rep. Gus Bilirakis (FL-12) joins colleagues asking for an update on promulgation of part 147.
Aug. 21, 2017: ATEC provides online webinar, Part 147: Where Are We Now? (Recorded version available for members).
Aug. 7, 2017: ATEC pens editorial in TheHill.com highlighting the issue and initiating grassroots efforts.
Aug. 2, 2017: Rep. Lamar Smith (TX-21) sends congressional inquiry asking for an update on rulemaking efforts.
June 28, 2017: ACS working group makes formal recommendation to ensure the new part 147 takes into account the ACS, and ensures that training and testing are correlated.
May 29, 2017: ATEC facilitates FAA-requested survey of AMTS to support agency economic analysis for rulemaking.
May 18, 2017: ATEC submits recommendation for utilization of AMTS fixed locations to support dual enrollment programs.
2016
Sept. 9, 2016: ATEC holds face-to-face meeting to provide further information in support of a competency-based rule.
May 17, 2016: ATEC submits supplemental comments supporting a competency-based part 147 regulation.
Feb. 22, 2016: The STEM Education Coalition, an alliance of more than 500 business, education and professional organizations, submitted comments to the part 147 notice of proposed rulemaking in support of ATEC's efforts.
Feb. 12, 2016: FAA Administrator Huerta responds to congressional letter stating that part 147 "is among the highest priority".
Feb. 1, 2016: ATEC submits comments to part 147 NPRM. In a separate submission, 14 organizations decried the NPRM’s continued reliance on class time at the expense of technical capability.
Jan. 13, 2016: Congressional leaders, prompted by ATEC, send letter to FAA calling for swift action on part 147 rulemaking.
2015
Nov. 19, 2015: FAA issues notice of proposed rulemaking for part 147.
2009
Jan. 8, 2009: Industry working group recommended broad changes to the current part 147.