Federal Aviation 

Administration 

Memorandum 

Date: 

To: 

From: 

Subject: 

September 09, 2016 

Docket FAA-2015-3901 

Aviation Maintenance Technician Schools 

Robert Warren, Aviation Safety Inspector, AFS-350 

Ex Parte Communication with Aviation Technician Education Council summary 

Notes 

On September 9, 2016, Federal Aviation Administration (FAA) officials and Aviation Maintenance 

Technician School (AMTS) representatives gathered at the Aviation Technician Education Council 

(ATEC) annual Washington Fly-in. The meeting was held at the Helicopter Association International 

headquarters in Alexandria, Virginia. The following staff from the FAA attended this meeting: 

Tim Shaver, Manager, Aircraft Maintenance Division, FAA 

Rolandos Lazaris, Deputy Assistant Manager, Aircraft Maintenance Division, FAA 

Kevin Morgan, Supervisory Aviation Safety Inspector, FAA 

Robert Warren, Aviation Safety Inspector, FAA 

The purpose of the "listening session" was for industry to provide feedback and voice concerns on 

regulatory matters surrounding governance of AMTS through 14 Code of Federal Regulations part 

147. Issues presented included encouragement of AMTS and high school partnerships, availability and 

bandwidth of designated mechanic examiners and the benefits and challenges associated with a part 

14 7 regulation that would allow AMTS to develop competency-based programs. 

Given that part 14 7 is currently in rulemaking, the agency requested that this summary be made available 

for public inspection. 

Attachment: 

Meeting Notes 
Aviation Technician Education Council and Federal Aviation Administration 

Summary of Oral Communications re Part 147 

Friday, Sept. 9, 2016 10:30 AM-12:00 PM 

FAA officials and aviation maintenance technician school (AMTS) representatives gathered at the 

Aviation Technician Education Council (ATEC) annual Washington Fly-in. The meeting was held at the 

Helicopter Association International headquarters in Alexandria, Virginia. Attendees included: 

• Tim Shaver, Manager, Aircraft Maintenance Division, FAA 

• Rolandos Lazaris, Deputy Assistant Manager, Aircraft Maintenance Division 

• Kevin Morgan, Supervisory Aviation Safety Inspector, FAA 

• Robert Warren, Aviation Safety Inspector, FAA 

• Butch Adams, Campus Director, Pittsburgh Institute of Aeronautics- Hagerstown 

• Ronald Donner, Chief Editor, AMT Magazine 

• Fred Dyen, Vice President, Blue Ridge Community College 

• Joseph Garcia, Aviation Maintenance Instructor, Lively Technical Center 

• Ryan Goertzen, Chief Aviation and Academic Officer, Spartan College of Aeronautics & 

Technology 

• Donald Gregson, Senior Vice President of University Operations, Hallmark University 

• Brad Hanselman, Director, Tulsa Technology Center 

• Gary Hoyle, Director of Campus Operations, Pittsburgh Institute of Aeronautics- Youngstown 

• Darrelllrby, DP Chairperson, Tarrant County College 

• Jocelyn lrby, Lawyer/Partner, The lrby Law Firm 

• Amy Kienast, Director of Career Services, MIAT College ofTechnology 

• Michael Mackey, Manager, TechOps Training, Delta Air Lines, Inc. 

• Crystal Maguire, Executive Director, Aviation Technician Education Council 

• Dennis Manzo, President, Spartan College of Aeronautics & Technology- Los Angeles 

• Sheryl Oxley, Aviation Program Coordinator, Tulsa Technology Center 

• Kim Pritchard, Sr. Mgr. Technician Recruitment, United Airlines 

• Andrew Smith, Associate Professor, Kansas State University- Salina 

• Art Spengler, Vice President, Premier Aircraft Sales, Inc. 

• Donald Stark, Airframe & Powerplant Coordinator, Sinclair Community College 

• Harold Summers, Director, Flight Operations & Technical Services, Helicopter Association 

International 

The purpose of the "listening session" was for industry to provide feedback and voice concerns on 

regulatory matters surrounding governance of AMTS through 14 Code of Federal Regulations part 147. 

Issue presented included encouragement of AMTS and high school partnerships, availability and band 

width of designated mechanic examiners and the benefits and challenges associated with a part 147 

regulation that would allow AMTS to develop competency-based programs. Given that part 147 is 

currently in rulemaking, the agency requested that this summary be made availble for public inspection. 

Roundtable participants spoke on the benefits and limitations of a rule that would allow AMTS to 

develop competency-based programs, whereby the agency sets the testing standards and provides 

AMTS the opportunity to meet those standards free from prescriptive requirements (seat time, subject 

requirements, etc.). 

Specifically, AMTS representatives requested that the final rule be issued without language that would 

require a specific number of program hours. Participants pointed out that competency-based systems 
Summary of FAA-ATEC oral communications re part 147 rulemaking 

Page 2 of 2 

are widely-supported by the education community including the Department of Education, and are 

proven to provide efficient and effective educational programs for the future workforce. Removing 

prescriptive requirements from the proposed rule would also be in line with the agency's efforts to 

implement risk-based oversight. That is, given the low-risk associated with AMTS, FAA resources 

currently utilized to enforce regulatory requirements such as grading systems, seat time, availability of 

missed material, etc. could be better utilized in higher risk areas (air carrier oversight, etc.). Further, 

AMTS operations and the manner in which it educates its students are better overseen by Department 

of Education and accreditors. 

Industry representatives also addressed potential concern in the local inspector's ability to enforce a 

competency-based rule, and measure the effectiveness of its program. AMTS representatives pointed 

out that the current rule does not provide the framework to measure program effectiveness (i.e., 

inspector checklists are focused on attendance records and grading policies), and that the AMTS 

"effectiveness" would utimately be measured through the mechanic test standards, which the FAA 

controls. Utimately, the agency will only issue a mechanic certificate to those applicants that possess the 

requisite skill and knowledge, as provided for in the written, oral and pratical tests set forth by the 

agency. 

Industry representatives also addressed the development of new airman certification standards (ACS) 

and how those standards should be utilized in the final rule. Once the ACS is developed, the standards 

could be incorporated into an AMTS operations specifications, to include specific objectives and 

teaching levels as needed. That way the AMTS would be "required" (through op specs) to teach those 

items provided for in the mechanic test. 

In closing, industry asked the agency to duly consider the benefits of allowing AMTS to impliment 

modern educational systems that other industries have long utilized. They asked agency representatives 

to permit programs that 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. This type of rule would encouage free-flow of A&P mechanic applicants to an 

industry that desperately needs a compitent and qualified workforce to support continued operations.