It is no secret that aviation maintenance personnel are in high demand. A study by the Aeronautical Repair Station Association suggests that the technician shortage is costing the U.S. MRO industry $1.4 billion annually in lost revenue. In response to the staggering number—expected to increase if industry forecasts come to fruition—the community is homing in on barriers to workforce growth. A recent initiative targets a regulatory framework that educators say creates challenges for airframe and powerplant (A&P) programs looking to expand their reach into high schools.
Around one-third of the aviation maintenance workforce is made up of certificated mechanics. Aircraft maintenance technician schools (AMTS)— certificated by the FAA through Title 14 Code of Federation Regulations (CFR) Part 147—create 63% of all new mechanics (the remainder obtain certification by virtue of their civil or military experience). The Aviation Technician Education Council (ATEC) estimates that AMTS need to increase production by 30% to meet projected industry demand for certificated mechanics over the next 20 years. Unfortunately, FAA data indicates that AMTS enrollments are shrinking, not growing. Nationally, A&P student populations have decreased 2% since 2014.
Schools and employers are looking for ways to reverse the trend. One common and increasingly popular strategy to increase enrollment and program awareness is through the development of high school partnerships, whereby high school students can begin mechanic coursework earlier in their educational careers.
“It’s a win-win for the student and industry,” said Tulsa Tech Aviation Programs Coordinator Sheryl Oxley. “The A&P classes are free to the public high school student, and dual enrollment programs provide the student an opportunity to get a head start on the hours required to become a full-blown mechanic.” On the flip side, Oxley says, dual enrollment programs provide industry an opportunity to make aviation careers more accessible and expand the number of individuals that ultimately decide to enroll in an A&P program.
High school students enrolled in Tulsa Tech’s aviation maintenance program graduate with up to 700 hr. of A&P program credit, 75% of what is required for an associate degree. “After high school, the students must complete one more year of coursework to qualify to take their mechanic exam,” said Oxley. “We have 19-year-olds beginning a career with starting pay of $40,000 per year, and it only cost them around $5,000 in college tuition to get their A&P certificate.”
Similar programs exist across the U.S. In most cases, the high school students are bused onto the AMTS campus to complete the coursework. Alternatively, an AMTS can help facilitate content delivery at a high school campus and award credit for “previous experience” (allowable under
§147.31(c)) if the student enrolls in the A&P program after high school graduation.
ATEC is calling on the agency to make policy changes that would allow schools to take these dual enrollment programs one step further. The current regulatory structure does not support the delivery of AMTS content to enrolled students away from its “primary location.” That is, a Part 147 certificated school may not provide its curriculum at a neighboring high school and bestow upon that high school student AMTS credit without that student first enrolling in the A&P program.
While the regulation does not prohibit AMTS from providing coursework at another location, FAA “endorsement” of the practice varies across local offices, with some officials expressly forbidding it. Local inspectors prohibiting the AMTS from providing content “away from the fixed location” often cite FAA guidance material that says schools may not “operate a satellite facility” and that “all AMTS must be FAA-certificated as separate facilities.” Notwithstanding the fact that guidance cannot impose requirements or prohibitions, it is safe to say that the language has discouraged the proliferation of dual enrollment programs.
The FAA addressed the issue in its recent Part 147 supplemental notice of proposed rulemaking (SNPRM), offering regulatory language that would provide for the approval of “satellite facilities.” ATEC maintains that the SNPRM is overly cumbersome and would unnecessarily create a new set of approvals that would dissuade many AMTS from opening satellite facilities.
In a recent letter to the agency, ATEC proposes a different approach. The council recommends that the agency utilize “additional fixed locations” operations-specifications templates for Part 147 certificate holders, as it does for Part 145 repair stations. This simple approach, one familiar to local inspectors and many AMTS
administrators given its common use in repair station operations, would allow schools to provide content away from its fixed location and subject to FAA oversight.
Under the framework, the FAA could more easily facilitate dual enrollment programs that—in their simplest form—provide opportunities for high school students to complete the general portion of the Part 147 curriculum. The high school student’s successful passage of the mechanic general knowledge exam (allowable under an “early testing” exemption) would give the student a head start at any A&P school and provide the highly coveted “certification” high schools often need to secure state funding of technical programs.
“The idea that aviation maintenance courses taken at any area high school would garner the student the same credit as if he or she took it at the main campus would open doors for a lot of Tulsans,” said Oxley. “There are plenty of local schools that would take us up on that opportunity, especially if they were able to secure additional funding to support it.”
According to a 2017 ATEC survey, only 8% of AMTS have high school dual enrollment programs. Out of the 62 respondents (representing 36% of all AMTS), 66% said that if the FAA regulation provided the opportunity, they would partner with a high school to offer courses away from their fixed location.