The PARTT 147 Act, impact on planning for new programs

Q: I read the recent article regarding the FAA Part 147 bill. I am confused as there was a recent NPRM that was issued and I was under the impression there was a mandate already to implement within a certain period after the comments were closed and responded to. Will this bill override that FAA proposal or will it require movement on it?

I ask because since the first ATEC conference I attended many years ago, the discussion was around the rewrite. We are considering opening a new maintenance training facility and are very interested in the timeline for a new rule.

A: Yes, you are correct that the FAA reauthorization bill mandated FAA promulgation of part 147 by April 5, 2019. While that date has passed, we are being told by the FAA that it won’t have a final rule out until at least summer 2021. Understandably there are some steps the agency has to take to look through and disperse comments received in response to the 147 SNPRM, but we are not even convinced that the agency would adhere to that timeline given past experience.
 
The PART 147 Act would direct the agency to remove the current part 147, and replace it with the language in the bill. So yes, it would bypass language that the agency has already proposed, but would be in line with the council’s comments and suggestions to both the NPRM and the SNPRM.
 
So, we are looking at a 2+ year timeline for the FAA to promulgate a final part 147 without the “legislative intervention.” If the bill becomes law, it would speed up the process, and we think we’d get a much better rule out of the deal.
 
We’ve been advising all our “new” schools to create curriculum in line with emerging airman certification standards (ACS) which are expected to govern the A&P mechanic test as soon as they are officially published (expected this summer). The school would have to make some tweaks to ensure its curriculum also complies with part 147 (until that rule is revised), but it will be in a much better position once the regulatory process is complete.