Printed headline: Just Consider It
Should aviation maintenance-technician training correlate to testing? An aviation rulemaking advisory committee (ARAC) working group tasked with developing a new Aviation Maintenance Technician (AMT) Airman Certification Standard (ACS) thought so and offered the suggestion to the FAA last year. After receiving an unfavorable response, the group countered that the agency’s unwillingness to align testing and training will create an undue burden and waste resources.
Work on the AMT ACS is underway, and once the standard is implemented, it will govern future development of the mechanics’ written, oral and practical tests, as well as the associated handbooks and guidance. The purpose of the FAA-industry initiative is to communicate clearly what a mechanic applicant needs to know and do to earn an airman certificate. It also should develop a process for continual review and revision.
An anticipated revision to Part 147, the regulation governing aviation maintenance-technician school curriculum requirements, provided what the working group saw as an opportunity to better correlate training and testing. It therefore made a recommendation that once static curriculum requirements are removed from Part 147, educational institutions use the AMT ACS as the standard for a training curriculum.
“This would ensure that FAA testing standards and aviation maintenance schools are working off the same sheet of music,” says Jackie Spanitz, AMT ACS subgroup co-chair and Aviation Supplies and Academics curriculum director. “Since the AMT ACS will be continually reviewed and revised through the ARAC working group, it will also ensure that both training and testing are in line with industry needs as technology evolves.”
Consistency between testing and training is something the education community has yet to experience. Spartan College of Aeronautics and Technology Denver Academic Dean Tim Guerrero often struggles with a disjointed system. “As an instructor, I am bound to teach Part 147 curriculum. But the examiners assess an applicant based on practical test standards,” explains Guerrero. “What the agency requires we teach in the classroom and what it expects a mechanic certificate applicant to know are not always in agreement,” he says.
A common irregularity stems from required subject area “teaching levels” that do not meet testing standard expectations. For example, Part 147 requires a school to teach general principles of wooden structure inspection. A correlating element on the practical test requires demonstration of a wood structure inspection. “The seemingly small variance can have a real impact on the applicant’s final test score,” says Guerrero.
To ensure students are properly prepared, the school must be diligent. If it determines curriculum changes are needed to better align with the test, it must first obtain FAA approval of the revision. The regulation also requires special dispensation for schools that want to teach to a higher level than those mandated by Part 147.
Once the ACS is published, matters could be made worse, since FAA aviation maintenance-technician handbooks—a commonly used resource for schools and students—will be revised to align with the new testing standard. This means that the school curriculum could further depart from subject matter presented in student and instructor textbooks.
The FAA Aircraft Maintenance Division disagreed with the working group’s suggestion that training organizations use the AMT ACS as the basis for a curriculum. In a March 7 response, the agency said it will instead base curriculum requirements on a framework developed by another ARAC working group, tasked in 2007 with recommending Part 147 revisions. Once removed from Part 147, curricula will be mandated through a certificate holder’s operations specifications. A maintenance training review board (MTRB), another brainchild of the previous working group, would thereafter “provide curriculum recommendations to the FAA every two years.”
In its letter, the FAA stated that it “recognize[d] that alignment of . . . training requirements, with any testing standards developed by the ACS [working group], will require collaboration and coordination between responsible offices to ensure appropriate consistency between those requirements.”
The working group took issue with the agency’s reasoning in its response, which was made part of a June ARAC quarterly meeting report. The group contends that the agency’s proposed actions would create “unnecessary inconsistencies, undue burdens for training organizations, and a waste of government resources.” Given the FAA’s reliance on a decade-old recommendation, issued before the ACS was conceived, it asserts that “reliance on old information to the detriment of new initiatives does a disservice to the industry and all hard-working [volunteers] and agency participants.”
With regard to the MTRB, the working group says it is unnecessary and would only enable a greater divide between testing and training. “The previous ARAC working group recommended a vehicle that would ensure training is ever-aligned with industry needs. The ACS, if utilized as a standard for both training and testing, serves that purpose and more,” says Spanitz. “And given that previous ARAC recommendations were utilized in the creation of the AMT ACS, the agency need not worry that those proposals were made in vain.”
The AMT ACS working group meets quarterly to continue developing the new testing standards—expected to publish in 2020. The agency has said it will issue a supplement to its 2015 Part 147 notice of proposed rulemaking later this summer.