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How Did We Get Here?

How Did We Get Here?. General Accounting Office (GAO) Report Number 03-317, March 2003 In March of 2003, a GAO Report detailed a serious and growing gap between the minimum training curriculum as required by Part 147 and the current and forecast levels of aircraft technology.

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How Did We Get Here?

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  1. How Did We Get Here? General Accounting Office (GAO) Report Number 03-317, March 2003 In March of 2003, a GAO Report detailed a serious and growing gap between the minimum training curriculum as required by Part 147 and the current and forecast levels of aircraft technology.

  2. In Response to the GAO Report . . . A Part 147 Working Group was formed. The group has completed its recommendations in a final report to the FAA`s EXCOM committee December 2008. The report contained 11 recommendations: • 5 recommendations are specific changes to existing rule • 1 recommendation creates a training specification for 14 CFR Part 147 • 1 recommendation creates a periodic curriculum review process • 6 recommendations relate to the modification and/or creation of courses and documents

  3. Recommendations Recommendation 1: Creation of a Part 147 Training Specification and resulting rule change to 147.5(b) • Creation of a training specification for easier operations and updating of dynamic areas such as curriculum. The training specification also contains the curriculum subject area topics. This expands on the existing reference to operations specifications in 14 CFR Part 147.5.

  4. Recommendations Recommendation 2: Modify Appendices A – D • The curriculum subjects areas are updated and are maintained in the rule. • A new method of dual teaching levels using knowledge and skill is further recommended. • Level 1, 2, & 3 skill sets remain unchanged.

  5. Training Specification The certificate holder will be required to develop an approved curriculum covering the following example elements base on training specifications. The training for airman qualifications, ratings, and certifications remain in accordance with 14 CFR Parts 65 and 147 as currently written: Table 1: General Curriculum Subjects & Topics ElementsKnowledge - Skill Level Fundamental Electricity / Electronics C-3 Electron theory B-2 Magnetism A-1

  6. Training Specification Knowledge Levels A. Be Familiar with basic facts. B. Knows general principals. C. Understands principals and apply the understanding.

  7. Training Specification Skill Levels 1. No Skill Demonstration Required. 2. Competent – Be able to define and interpret. 3. Proficient – Performs skill operations to a simulated return-to-service.

  8. Recommendations Recommendation 3: Creation of the Maintenance Training Review Board • A review board is created that would perform a biennial review of the AMTS 147 curriculum and recommend changes to the FAA. The board will be made up of Aviation Technician Education Council members, industry and trade or professional association members along with FAA HQ and field level representatives.

  9. Recommendations Recommendation 4: Changes to CFR Part 147.21(b) and 147.21(c) • The minimum training hours specified in Part 147.21(b) are maintained at 1900 (combined airframe and powerplant) but are redistributed. A new distribution of 450 hours general, 800 airframe, and 650 powerplant are recommended. Part 147.21(c) also adds new reference to training specification.

  10. Recommendations Recommendation 5: Include Part 147 in Draft Advisory Circular “Alternatives to Classroom Training” (Dated: 9/27/05) and Finalize • Improvements in technology require147 schools to be allowed to use alternative delivery methods where appropriate. A draft AC 147-3 B will be revised to include Part 147 alternative delivery procedures and be hopefully finalized along with the developing rule process.

  11. Recommendations Recommendation 6: Changes to 14 CFR Part 147.31 • Clarification of terms, definitions, and processes are made to improved consistency in interpretation. • These areas are primarily in the attendance, enrollment, test and credit for prior instruction or experience areas of the existing rule language.

  12. Recommendations Recommendation 7: Formalizing the Exemption Process • The FAA routinely grants exemptions to allow student who have completed the General curriculum to take the written examination prior to completion of the airframe and/or powerplant curricula. New language in Part 147.35 eliminates the need for granting future exemptions for General testing in these situations.

  13. Recommendations Recommendation 8: Creation of a Specific TRAINING Course to include Surveillance/ oversight and 147 certification for FAA Principle Inspectors • Currently there is no specific courses available for inspectors with AMTS surveillance responsibilities. A dedicated course will improve consistency of guidance interpretation and regulatory knowledge for Inspectors assigned AMTS 147 oversight.

  14. Recommendations Recommendation 9: Review and Update of Advisory Circular AC 147.3A Recommendation 10: Review and Update of the Practical Test Standards and Knowledge Tests for airman (AMTs)

  15. Recommendations Recommendation 11: Review and Update of 8900.1 Guidance While updating of documents related to rule such as advisory circulars and practical test standards is mandated, time limits for revision are not provided.

  16. ATEC Feedback & Input • The preliminary recommendations were presented to ATEC in September for review. • ATEC comments were reviewed and addressed in the final recommendations made by the working group to the EXCOM and FAA management. • ATEC also participated in crafting of the final recommendations during the November 2008 ARAC working group meeting.

  17. Summary • Since creation of the CFR Part 147 Working Group in June 2007, we have had six (6) face to face work sessions. • The 11 recommendations address the current issues expressed within Part 147 to the extent we believe possible today. • The creation of the training specification, transfer of curriculum subject topics to the training specification, and the biennial review process allow CFR Part 147 to adapt and evolve with industry technology for the foreseeable future.

  18. Conclusion • The recommendations being offered provide a significant improvement to CFR Part 147, the Aviation Industry and resulting product. A well trained technician (AMT) • Recommendations allow Industry to play a role in our work and providing leadership during implementation and periodic review of training requirements, thus ensuring the needs of FAA, and 147 schools are addressed in balance with industry needs. • The EXCOM committee reviewed recommendations as submitted and approved as submitted to enter the second phase of the FAA rule making process.

  19. Conclusion An RPR will be published in the Federal Register for public comment at a later date and an FAA team established to develop the NPRM language. Considerable work remains before the final product is realized and once again the FAA welcomes all input provided throughout the NPRM process and resulting comment period.

  20. Questions??

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