Last month, the agency published the long-awaited supplemental notice of proposed rulemaking (SNPRM) for Title 14 CFR part 147, the regulation governing aviation maintenance technician schools.
The proposal "supplements" the agency's 2015 notice of proposed rulemaking, which recommended removal of static curriculum requirements and allowance for a credit-hour system. ATEC and others called for more flexibility that would allow for competency-based programs and expansion of curriculum into high schools. The SNPRM makes additional proposals to address those concerns.
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 will reiterate 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 will ask that the agency 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.
