# Federal Aviation Administration 

# Memorandum
Date: To:
From: Subject: September 09, 2016 DocketFAA-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 stafffrom 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 ofthe "listening session" was for industry to provide feedback and voice concerns on regulatory matters surrounding governance ofAMTS through 14 

### Code ofFederal Regulations part 147
.Issues presented included encouragement ofAMTS and high school partnerships, availability and bandwidth ofdesignated mechanic examiners and the benefits and challenges associated with apart 14

### 7 regulation that would allow AMTS to develop competency-basedprograms. Given that part 14

### 7 is currently in rulemaking,the agency requested that this summary be made available for public inspection.
Attachment: MeetingNotesAviation Technician Education Council and Federal Aviation Administration Summary of Oral Communications re Part 147 Friday, Sept. 9, 2016 10:30AM-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 atthe HelicopterAssociation 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 ofAeronautics- 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, ChiefAviation and Academic Officer, Spartan College ofAeronautics & Technology • Donald Gregson, SeniorVice President of University Operations, Hallmark University • Brad Hanselman, Director, Tulsa Technology Center • Gary Hoyle, Director ofCampus Operations, Pittsburgh Institute ofAeronautics- Youngstown • Darrelllrby, DP Chairperson, Tarrant County College • Jocelyn lrby, Lawyer/Partner, The lrby Law Firm • Amy Kienast, Director ofCareer 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 ofAeronautics & 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, PremierAircraft Sales, Inc. • Donald Stark, Airframe & Powerplant Coordinator, Sinclair Community College • Harold Summers, Director, Flight Operations & Technical Services, HelicopterAssociation International The purpose ofthe "listening session" was for industry to provide feedback and voice concerns on regulatory matters surrounding governance ofAMTS through 14 Code of Federal Regulations part 147. Issue presented included encouragement ofAMTS and high school partnerships, availability and band width ofdesignated 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 ofa rule that would allow AMTS to develop competency-based programs, whereby the agency sets the testing standards and provides AMTS the opportunityto 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 numberof program hours. Participants pointed outthat competency-based systemsSummary of FAA-ATEC oral communications re part 147 rulemaking Page 2of2

are widely-supported by the education community including the Department of Education, and are proven to provide efficient and effective educational programs forthe 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 betteroverseen by Department of Education and accreditors

. Industry representatives also addressed potential concern in the local inspector's abilityto 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 ofnew airman certification standards (ACS) and howthose 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) toteach those items provided for in the mechanic test
. In closing, industry asked the agency to duly considerthe benefits ofallowing 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 ofastructure that creates flexibility, and allows studentsto progress as they demonstrate mastery ofsubject matter, regardless oftime, place, or pace of learning

.This type of rule would encouage free-flow ofA&P mechanic applicants to an industry that desperately needs acompitent and qualified workforce to support continued operations

.