Federal Aviation
Administration
14 CFR Part 147
Aviation Advisory
Committee Working
Group Training Updates
Presented to: World Aviation Training Symposium
and Trade Exposition
By: Edward L. Hall, AFS-350
Date: April 27, 2009
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.
14 CFR Part 147 Aviation Advisory Committee Working Group Training Updates
April 27, 2009
Federal Aviation
Administration
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
14 CFR Part 147 Aviation Advisory Committee Working Group Training Updates
April 27, 2009
Federal Aviation
Administration
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.
14 CFR Part 147 Aviation Advisory Committee Working Group Training Updates
April 27, 2009
Federal Aviation
Administration
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.
14 CFR Part 147 Aviation Advisory Committee Working Group Training Updates
April 27, 2009
Federal Aviation
Administration
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
Elements
Fundamental Electricity / Electronics
Electron theory
Magnetism
14 CFR Part 147 Aviation Advisory Committee Working Group Training Updates
April 27, 2009
Knowledge - Skill Level
C-3
B-2
A-1
Federal Aviation
Administration
Training Specification
Knowledge Levels
A. Be Familiar with basic facts.
B. Knows general principals.
C. Understands principals and apply the
understanding.
14 CFR Part 147 Aviation Advisory Committee Working Group Training Updates
April 27, 2009
Federal Aviation
Administration
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.
14 CFR Part 147 Aviation Advisory Committee Working Group Training Updates
April 27, 2009
Federal Aviation
Administration
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.
14 CFR Part 147 Aviation Advisory Committee Working Group Training Updates
April 27, 2009
Federal Aviation
Administration
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.
14 CFR Part 147 Aviation Advisory Committee Working Group Training Updates
April 27, 2009
Federal Aviation
Administration
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.
14 CFR Part 147 Aviation Advisory Committee Working Group Training Updates
April 27, 2009
Federal Aviation
Administration
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.
14 CFR Part 147 Aviation Advisory Committee Working Group Training Updates
April 27, 2009
Federal Aviation
Administration
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.
14 CFR Part 147 Aviation Advisory Committee Working Group Training Updates
April 27, 2009
Federal Aviation
Administration
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 CFR Part 147 Aviation Advisory Committee Working Group Training Updates
April 27, 2009
Federal Aviation
Administration
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)
14 CFR Part 147 Aviation Advisory Committee Working Group Training Updates
April 27, 2009
Federal Aviation
Administration
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.
14 CFR Part 147 Aviation Advisory Committee Working Group Training Updates
April 27, 2009
Federal Aviation
Administration
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.
14 CFR Part 147 Aviation Advisory Committee Working Group Training Updates
April 27, 2009
Federal Aviation
Administration
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.
14 CFR Part 147 Aviation Advisory Committee Working Group Training Updates
April 27, 2009
Federal Aviation
Administration
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.
14 CFR Part 147 Aviation Advisory Committee Working Group Training Updates
April 27, 2009
Federal Aviation
Administration
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.
14 CFR Part 147 Aviation Advisory Committee Working Group Training Updates
April 27, 2009
Federal Aviation
Administration
Questions??
14 CFR Part 147 Aviation Advisory Committee Working Group Training Updates
April 27, 2009
Federal Aviation
Administration