A Competency-Based 147: A Full Scholarship for Employers

Title 14 Code of Federal Regulations (CFR) part 147, the regulation governing aviation maintenance technician schools (AMTS), has not been significantly updated in more than 50 years. Given the wild advances in technology since that time, the law mandates AMTS teach many skills that aren’t even used in the real aviation world. After the tuition checks are deposited, industry is left holding the bill for actually ensuring graduates are capable of completing the basic tasks required to maintain a modern, sophisticated aircraft.

After years of planning and effort by industry and regulator working groups, a notice of proposed rulemaking was released in October 2015. The proposal would make a lot of needed changes, most importantly removing specified curriculum and hour provisions that require each AMTS to pour resources into teaching outdated technologies. It would also allow for a credit-based system, which brings the regulation in line with Department of Education requirements and guidelines.

There is still room for improvement. Industry desperately needs competency-based guidelines that allow institutions to cater programs to the needs of employers. The proposal does not provide for such frameworks; in fact it contains many specifics carried over from the current rule that fly in the face of a competency-based program.

For instance, the proposed rule would require that “[t]he system … show hours of absence allowed, and show how the missed material and hours will be made available to the student.” While making missed material available to students is a completely rational idea – one that arguably need not be dictated through regulation – agency guidance has interpreted the regulation to mean that all missed projects and assignments must be “made up” and the manner in which that must be accomplished (see Order 8900.1, Vol. 2, Ch. 12, Section 1 and Section 3 and Advisory Circular [AC] 147-3B). This has led to wasted time and increased costs for the AMTS community, forced to re-teach outdated content to students, many of whom may already be deemed competent in the subject matter.

Similar challenges are presented by requiring specific student/teacher ratios and “passing norms,” the inability to teach above defined curriculum levels without FAA approval, and requiring approval of instructor rosters. These prescriptive, inflexible regulations will not ensure a qualified workforce.

Put simply, the proposal maintains its predecessor’s antiquated concern with the time a student spends in a classroom seat at the expense of the skills he or she actually gains. A competency-based standard, free of defined schedules and specific hour requirements, will allow industry to transition away from seat time in favor of a structure that creates flexibility, and allows students to progress as they demonstrate mastery of subject matter, regardless of time, place, or pace of learning. A flexible framework would also further other educational initiatives including distance learning, dual enrollment programs with secondary education, and project-based learning.

Fixing 147 is an industry imperative. Handicapping our schools burdens both graduates and employers – imposing costs on the entire aviation community. Let’s all step back and consider a wildly new approach that would allow the educational system to provide the best workforce through the most efficient means. To do that we need to let the educators do what they do best, and get the regulators out of the teaching business.

Crystal Maguire is senior managing associate of Obadal, Filler, MacLeod and Klein, P.L.C. advising clients in international aviation safety regulation and government affairs. She serves as vice president of operations for the Aeronautical Repair Station Association and business manager for the Aviation Technician Education Council.